EPA/ROD/R09-02/635 2002

EPA Superfund Record of Decision:

ANDERSEN AIR FORCE BASE EPA ID: GU6571999519 OU 04 YIGO, GU 07/02/2002 THE UNITED STATES AIR FORCE INSTALLATION RESTORATION PROGRAM

FINAL RECORD OF DECISION FOR HARMON ANNEX OPERABLE UNIT

ANDERSEN AIR FORCE BASE, GUAM

July 2002 THE UNITED STATES AIR FORCE INSTALLATION RESTORATION PROGRAM

FINAL RECORD OF DECISION FOR HARMON ANNEX OPERABLE UNIT

ANDERSEN AIR FORCE BASE, GUAM

July 2002 Form Approved REPORT DOCUMENTATION PAGE OMB No 0704-0188 Public reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to Washington Headquarters Services, Directorate for Information Operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington, VA 22202-4302, and to the Office of Management and Budget, Paperwork Reduction Project (0704-0188), Washington, DC 20503. 1 . AGENCY USE ONLY (Leave blank) 2. REPORT DATE 3. REPORT TYPE AND DATES COVERED July 2002 Final 4. TITLE AND SUBTITLE 5. FUNDING NUMBERS

Record of Decision for Harmon Annex Operable Unit, F-41 624-00-D-8052-003 Andersen Air Force Base, Guam Delivery Order 03 6. AUTHOR(S) Michael Bone, P.E. (Foster Wheeler Environmental Corporation) Toraj Ghofrani, P.E. (EA Engineering, Science, & Technology, Inc.)

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 8. PERFORMING ORGANIZATION REPORT NUMBER Foster Wheeler Environmental Corporation 43 Union Blvd., Suite 1010, Lakewood, CO 80228-1829 N/A

EA Engineering, Science, & Technology, Inc. P.O. Box 4355, Andersen AFB, Yigo, Guam 96929-4355 9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) 10. SPONSORING/MONITORING Air Force Center for Environmental Excellence AGENCY REPORT NUMBER HQAFCEE/ERD N/A 3207 North Road, Bldg. 532 Brooks Air Force Base, Texas 78235-5363 11. SUPPLEMENTARY NOTES

12a. DISTRIBUTION/AVAILABILITY STATEMENT 12b. DISTRIBUTION CODE Approved for public release; distribution is unlimited. 13. ABSTRACT (Maximum 200 words)

This Record of Decision presents the rationale behind a No Further Action decision for Installation Restoration Program (IRP) Site 18/Landfill 23, Site 19/Landfill 24, and Site 39/Harmon Substation located at Harmon Annex, Andersen Air Force Base, Guam. This Record of Decision summarizes the history, environmental background, extent of contamination, associated risks, implemented remedial alternatives, and the post-remedial status of the Harmon Annex Operable Unit. 14. SUBJECT TERMS 15. NUMBER OF PAGES Andersen AFB - Human Health Risk Assessment Remedial Investigation - Ecological Risk Assessment No Further Action 16. PRICE CODE 17. SECURITY CLASSIFICATION 18. SECURITY CLASSIFICATION 19. SECURITY CLASSIFICATION 20. LIMITATION OF ABSTRACT OF REPORT OF THIS PAGE OF ABSTRACT Unclassified Unclassified Unclassified UL NSN 7540-01 -280-5500 Standard Form 298 (Rev 2-89) Prescribed by ANSI Std 239-18 USAF-223-R 298-102 CONTENTS Page

LIST OF TABLES ii

LIST OF FIGURES iii

LIST OF ACRONYMS AND ABBREVIATIONS iv

1. DECLARATION 1-1 1.1 Site Name and Location 1-1 1.2 Statement of Basis and Purpose 1-1 1.3 Description of the Selected Remedy: No Further Action 1-1 1.4 Declaration Statement 1-1 1.5 Signature and Supported Agency Acceptance of the Remedy 1-2

2. DECISION SUMMARY 2-1 2.1 Site Name, Location, and Description 2-1 2.2 Site History and Enforcement Activities 2-4 2.3 Highlights of Community Participation 2-6 2.4 Scope and Role of the Operable Unit or Response Action 2-7 2.5 Site Characteristics 2-8 2.5.1 Sites 18, 19, and 39 Conceptual Model 2-9 2.5.2 Site 18 Contaminant Characteristics 2-9 2.5.3 Site 19 Contaminant Characteristics 2-10 2.5.4 Site 39 Contaminant Characteristics 2-12 2.6 Summary of Site Risks 2-14 2.6.1 Summary of Site 18 Risks 2-14 2.6.2 Summary of Site 19 Risks 2-15 2.6.3 Summary of Site 39 Risks 2-17 2.7 Description of No Further Action Alternative 2-21 2.7.1 No Further Action Alternative for Site 18 2-21 2.7.2 No Further Action Alternative for Site 19 2-21 2.7.3 No Further Action Alternative for Site 39 2-22 2.8 Explanation of Significant Changes 2-22

3. RESPONSIVENESS SUMMARY 3-1

4. REGULATORY COMMENTS AND AIR FORCE RESPONSES 4-1

5. REFERENCES R-l

APPENDIX A Andersen Air Force Base Administrative Record Index APPENDIX B IRP Sites 19 and 39 Confirmation Sample Results (IT/OHM, 1999) APPENDIX C Human Health and Ecological Risk Assessments (IT/OHM, 1999)

Final Record of Decision i July 2002 Harmon Annex Operable Unit LIST OF TABLES

Table Follows No. Title Page No.

2-1 Surface Soil Analytical Results for IRP Site 18, Andersen AFB, Guam 2-8 2-2 Groundwater Analytical Results for Monitoring Well IRP-37, Near IRP Site 18, Andersen AFB, Guam 2-10 2-3 Surface Soil Analytical Results for IRP Site 19, Andersen AFB, Guam 2-10 2-4 Subsurface Soil Analytical Results for IRP Site 19, Andersen AFB, Guam 2-10 2-5 Subsurface Soil Dioxin Results for IRP Site 19, Andersen AFB, Guam 2-10 2-6 Groundwater Analytical Results for Monitoring Well IRP-38, Near IRP Site 19, Andersen AFB, Guam 2-12 2-7 Surface Soil Analytical Results for IRP Site 39, Andersen AFB, Guam 2-13 2-8 Subsurface Soil Analytical Results for IRP Site 39, Andersen AFB, Guam 2-13 2-9 Sludge Analytical Results for the Oil/Water Separator at IRP Site 39, Andersen AFB, Guam 2-13 2-10 Liquid and Floating Product Sample Results for the Oil/Water Separator at IRP Site 39, Andersen AFB, Guam 2-13 2-11 Surface Soil Dioxin Analytical Results at IRP Site 39, Andersen AFB, Guam 2-13 2-12 Subsurface Soil Dioxin Analytical Results for IRP Site 39, Andersen AFB, Guam 2-13 2-13 Groundwater Analytical Results for Monitoring Well IRP-36, Near IRP Site 39, Andersen AFB, Guam 2-14 2-14 Remedial Action at IRP Site 19, Andersen AFB, Guam 2-16 2-15 Remedial Action at IRP Site 39, Andersen AFB, Guam 2-19 2-16 Summary of Pertinent ARARs for IRP Site 19 and 39, Andersen AFB, Guam 2-22

Final Record of Decision ii July 2002 Harmon Annex Operable Unit LIST OF FIGURES

Figure Follows No. Title Page No.

2-1 Location Map of Guam 2-1 2-2 Location Map of Andersen Air Force Base on Guam 2-1 2-3 Location Map of Harmon Annex Including IRP Sites 18,19, and 39 at Andersen AFB, Guam 2-1 2-4 Location of IRP Site 18/Landfill 23 at Harmon Annex, Andersen AFB, I Guam 2-1 2-5 Location of IRP Site 19/Landfill 24, Parcels A, B, and C at Harmon Annex, Andersen AFB, Guam 2-1 2-6 Location of IRP Site 39/Harmon Substation at Harmon Annex, Andersen AFB, Guam 2-1 2-7 Natural Habitats of IRP Site 18, Andersen AFB, Guam 2-2 2-8 Natural Habitats of IRP Site 19/Landfill 24, Parcels A, B, and C, Andersen AFB, Guam 2-2 2-9 Natural Habitats of IRP Site 39/Harmon Substation, Andersen AFB, Guam 2-3 2-10 Detailed Site Inventory Results at IRP Site 18, Andersen AFB, Guam 2-9 2-11 Soil Sample Locations and Results at IRP Site 18, Andersen AFB, Guam 2-9 2-12 Detailed Site Inventory Results at IRP Site 19/Landfill 24, Parcels A, B, and C, Andersen AFB, Guam 2-10 2-13 Surface Soil Sample Locations and Results at IRP Site 19/Landfill 24, Parcels A, B, and C, Andersen AFB, Guam 2-10 2-14 Subsurface Soil Sample Locations and Results at IRP Site 19/Landfill 24, Parcels A, B, and C, Andersen AFB, Guam 2-10 2-15 Detailed Site Inventory Results at IRP Site 39/Harmon Substation, Andersen AFB, Guam 2-12 2-16 Surface Soil Sample Locations and Results at IRP Site 39/Harmon Substation, Andersen AFB, Guam 2-13 2-17 Subsurface Soil Sample Locations and Results at IRP Site 39/Harmon Substation, Andersen AFB, Guam 2-13 2-18 Proposed Remediation Sites at IRP Site 19/Landfill 24, Parcels A, B, and C, Andersen AFB, Guam 2-15 2-19 Remediated Areas at IRP Site 19/Landfill 24, Parcels A, and C, Andersen AFB, Guam 2-16 2-20 Proposed Remediation Sites at IRP Site 39/Harmon Substation, Andersen Air Force Base on Guam 2-17 2-21 Remediated Areas at IRP Site 39/Harmon Substation, Andersen AFB, Guam 2-18

Final Record of Decision iii July 2002 Harmon Annex Operable Unit LIST OF ACRONYMS AND ABBREVIATIONS

AFB Air Force Base AOC Area of Concern ARARs Applicable or Relevant and Appropriate Requirements bgs below ground surface BTVs Background Threshold Values CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System CFR Code of Federal Regulations COC Constituent of Concern COPC Constituent of Potential Concern CSM Conceptual Site Model CRP Community Relations Plan CY Cubic Yards DAWR Department of Aquatic and Wildlife Resources DSI Detailed Site Inventory EA EA Engineering, Science, and Technology, Inc. EBS Environmental Baseline Survey EOD Explosive Ordnance Disposal /F degrees Fahrenheit ft feet FFA Federal Facility Agreement GEPA Guam Environmental Protection Agency GovGuam Government of Guam GSA General Services Administration GWA Guam Waterworks Authority HSWA Hazardous and Solid Waste Act of 1982 ICF ICF Technology, Inc. IRP Installation Restoration Program IT/OHM IT Corporation µg/kg micrograms per kilogram µg/L micrograms per liter MARBO Marianas Bonins Command MCL Maximum Contaminant Level mgd million gallons per day mg/kg milligrams per kilogram msl mean sea level NCP National Oil and Hazardous Substances Pollution Contingency Plan NCS U.S. Naval Communication Station NFA No Further Action NFRAP No Further Response Action Planned NGL Northern Guam Lens OU Operable Unit OSWER Office of Solid Waste and Emergency Response

Final Record of Decision iv July 2002 Harmon Annex Operable Unit LIST OF ACRONYMS AND ABBREVIATIONS (continued)

P.L. Public Law PACAF Pacific Air Force PAH polycyclic aromatic hydrocarbon PCBs poly chlorinated biphenyls PRG Preliminary Remediation Goal RAB Restoration Advisory Board RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RGO Remedial Goal Objective RI Remedial Investigation RL reporting limit ROD Record of Decision RPM Remedial Program Manager SARA Superfund Amendments and Reauthorization Act of 1986 SVOC semivolatile organic compound TEQ Toxicity Equivalent Quotient TPH Total Petroleum Hydrocarbons USAF United States Air Force USEPA United States Environmental Protection Agency USN United States Navy UXO Unexploded Ordnance VOC volatile organic compound WWII World War II

Final Record of Decision v July 2002 Harmon Annex Operable Unit 1. DECLARATION

1.1 Site Name and Location

Andersen Air Force Base (AFB), Harmon Annex Operable Unit (OU), Guam, USA

1.2 Statement of Basis and Purpose

This Record of Decision (ROD) is a legal technical document prepared for the Harmon Annex OU comprised of three Installation Restoration Program (IRP) sites at Andersen AFB in Guam. The three IRP sites are Site 18 (Landfill 23), Site 19 (Landfill 24), and Site 39 (Harmon Substation), including the groundwater underlying the sites. The purpose of this ROD is to present the public with a consolidated source of information regarding the history, environmental background, extent of contamination, associated risks, implemented remedial alternatives, and the post-remedial status of the Harmon Annex OU.

According to Chapter IX of the Interim Final Guidance on Preparing Superfund Decision Documents (USEPA, 1989a), this ROD is a "unique" case where remedial alternatives have already been implemented and No Further Action is proposed for the three Harmon Annex sites. The United States Air Force (USAF), the United States Environmental Protection Agency (USEPA) Region IX, and the Guam Environmental Protection Agency (GEPA) concur with the No Further Action decision presented in this ROD. The No Further Action is warranted because previous removal actions have already mitigated the sites, and the Harmon Annex OU poses no current or future threat to human health or the environment (USEPA, 1989a). Subsequently, the standard ROD formats have been modified to present the No Further Action decision in accordance with the Administrative Record for the sites and in compliance with 40 Code of Federal Regulations (CFR), Part 300. The CFR included the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), the Hazardous and Solid Waste Act of 1982 (HSWA), the Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous Substances Pollution Contingency Plain of 1990 (NCP).

1.3 Description of the Selected Remedy: No Further Action

1.4 Declaration Statement

The No Further Action alternative was recommended for Sites 18, 19, and 39. Based on the Final Remedial Investigation (RI) for Harmon Annex OU (EA, 2000), there was no supporting evidence that Site 18, covering approximately 42.2 acres, was ever used as a landfill. Subsequently, Site 18 was classified as an Area of No Suspected Contamination.

Sites 19 and 39 were used in part as landfills. Sites 19 and 39 cover approximately 28.1 and 8.3 acres, respectively. Debris and Constituents of Concern (COCs) were identified at some areas of the sites. The USAF decided to establish conservative cleanup standards based on the USEPA Region IX, Residential Preliminary Remediation Goals (PRGs) due to the urgency in transferring Harmon Annex sites to the Government of Guam (GovGuam). Based on mutual

Final Record of Decision 1-1 July 2002 Harmon Annex Operable Unit agreement between the USAF, USEPA Region IX, and GEPA, soil removal and off-site land disposal was selected as a cleanup alternative for Sites 19 and 39. This removal action was protective of human health and the environment and complied with federal and territorial (Guam) requirements that were legally applicable or relevant and appropriate. The groundwater beneath Sites 18, 19, and 39 is approximately 320 feet below ground surface (bgs) with a westward flow towards the Philippine Sea. No COCs were detected in the groundwater under Harmon Annex above the Maximum Contaminant Levels (MCLs), or PRGs for tap water, with the exception of chloroform, chromium, and nickel. These compounds do not represent groundwater contamination because chloroform is associated with laboratory contamination and chromium and nickel are attributed to corrosion of the stainless steel piston pump and well screen.

After removing the sources of all COCs, Sites 19 and 39 are classified as a Category IV, No Further Response Action Planned (USAF, 1995). Furthermore, the removing of any contaminant source was cost effective in providing a permanent solution for these sites and precluding long-term monitoring requirements as well as future five-year reviews that are associated with some other remedial alternatives.

1.5 Signature and Supported Agency Acceptance of the Remedy

The following signature pages document that the USAF, USEPA Region IX, and GEPA supported acceptance of the remedy.

Final Record of Decision 1-2 July 2002 Harmon Annex Operable Unit This signature page documents that the USAF supports acceptance of the remedy for the Harmon Annex OU.

______Eugene D. Santarelli Date Lieutenant General, U.S. Air Force Vice Commander, Pacific Air Forces

Final Record of Decision 1-3 July 2002 Harmon Annex Operable Unit This signature page documents that the USEPA Region IX supports acceptance of the remedy for the Harmon Annex OU.

______Daniel A. Meer Date Chief Federal Facilities Cleanup Branch U.S. Environmental Protection Agency, Region IX

Final Record of Decision 1-4 July 2002 Harmon Annex Operable Unit This signature page documents that the GEPA supports acceptance of the remedy for the Harmon Annex OU.

______Jesus Salas Date Administrator Guam Environmental Protection Agency

Final Record of Decision 1-5 July 2002 Harmon Annex Operable Unit 2. DECISION SUMMARY

This decision summary has been prepared for IRP Sites 18, 19, and 39 located at Harmon Annex. The purpose of this decision summary is to provide an overview of each site's description, environmental characteristics, history, public involvement, extent of contamination, associated human health and ecological risks, remedial alternatives, and rationale for implementing the remedy of choice in light of statutory requirements. A detailed RI report was completed for the above-referenced sites in November 2000 (EA, 2000).

2.1 Site Name, Location, and Description

Guam is the largest and southernmost island of the Mariana Islands in the western Pacific Ocean. Relative to Guam, Hawaii is 3,700 miles to the east and Japan is 1,560 miles to the north (Figure 2-1). Guam is approximately 30 miles long, varies in width from 4 to 12 miles, and has a total land area covering approximately 209 square miles.

Andersen AFB consists of multiple parcels of land located on the northern half of the island (Figure 2-2). The Main Base property includes the Main Base and Northwest Field and is about 8 miles wide, 2 to 4 miles long, and covers approximately 24.5 square miles. The Main Base is the center of active base operations and Northwest Field has been relatively inactive since the early 1950s. In addition to the Main Base and Northwest Field (which together cover 15,463 acres), Andersen AFB occupies other smaller areas to the south, including the Marianas Bonins Command (MARBO) Annex and the Harmon Annex (Figure 2-2). The MARBO Annex, covering 2,432 acres, lies about 4 miles south of the Main Base. The Harmon Annex, with 1,817 acres, is located approximately 4 miles south of Northwest Field.

The Harmon Annex is bordered by the U.S. Naval Communication Station (NCS) to the north, Marine Drive (Route 1) to the south, Route 3 to the east, and the coastal cliffline to the west (Figure 2-3). The Harmon Annex includes Site 18, Site 19, and Site 39, which are the focus of this ROD.

Site 18, with no buildings or structures, is located in an undeveloped area north of Harmon Village, approximately 300 feet north of Beach Road. In August 1992, a site reconnaissance was conducted that expanded the study boundary of Site 18 to cover approximately 42.2 acres, as shown in Figure 2-4. Site 19, with a total of 28.1 acres, is located just north of Harmon Village. Site 19 is comprised of Parcel A (9.4 acres), Parcel B (12.3 acres), and Parcel C (6.4 acres), which are separated by Beach Road, 10th Street, and 13th Street, respectively (Figure 2-5). With the exception of two concrete pads and one concrete slab at Landfill 24A, Site 19 includes no buildings or structures. Site 39 (8.3 acres) is located north of Marine Drive and adjacent to the Guam Power Authority Electrical Substation, across from the Micronesia Mall. Site 39 includes an oil/water separator, an electric vault, a cathodic converter, and a stormwater outfall as shown in Figure 2-6.

The Harmon Annex ranges in elevation from 220 feet to 320 feet mean sea level (msl) and Sites 18, 19, and 39 are approximately 310 feet, 280 feet, and 260 feet above msl, respectively. The

Final Record of Decision 2-1 July 2002 Harmon Annex Operable Unit

Harmon Annex resides in the region of the northern plateau, which consists of limestone reef deposits underlain by volcanic rocks. Groundwater resources are primarily found in the northern half of the island in porous limestone deposits of the Barrigada and Mariana Formations. Because fresh groundwater is lighter in weight as compared with seawater, groundwater floats on seawater as a lens-shaped body of freshwater in an approximate buoyant equilibrium. The groundwater-air interface at Harmon Annex is encountered at 2.66 feet to 4.29 feet above msl, approximately 320 feet bgs. The groundwater-seawater interface, however, is not well defined due to dynamic mixing of freshwater and seawater. This mixing zone (diffuse zone) is a layer of brackish water occurring at the bottom of a 106- to 171-foot-thick groundwater lens, depending on tidal changes, seasonal variation in precipitation, and withdrawals of freshwater by mechanical means (Mink, 1976).

Guam lies about 900 miles north of the equator, which creates a year-round warm climate. The mean annual temperature is approximately 81 degrees Fahrenheit (/F) and temperatures range from the low 70s to the low 90s /F. There are two seasons on Guam, a wet season that extends from July to November, and a dry season that extends from December to June. The mean monthly temperatures range from 80 /F during January to about 83 /F in June (Ward et al., 1965). Humidity ranges between 65 to 80 percent in the late afternoon and 85 to 100 percent at night, with a monthly average of 66 percent. The trade winds are dominant from the east or northeast, with wind speed ranging between 4 and 12 miles per hour throughout the year. These winds are the strongest during the dry season, averaging 15 to 25 miles per hour. During the wet season, the trade winds are still dominant, but less frequent. The winds can blow from any direction with wind speeds generally less than 15 miles per hour. Storms may occur at any time during the year, but are most common during the wet season. The ambient air quality of Guam remains relatively clean at all times due to prevailing winds of clean air from the ocean.

Many natural habitat communities on Guam have been destabilized by the introduction of non-native species. Consequently, several of the native flora and fauna of Guam are considered threatened or endangered species (DAWR, 1994). However, no threatened or endangered species have been encountered in the vicinity of Sites 18, 19, and 39. A site-specific flora and fauna survey has been conducted for Sites 18, 19, and 39 and the results are as follows.

The flora at Site 18 includes approximately 40 percent Mixed Herbaceous and 60 percent Mixed Shrubs (Figure 2-7). Mixed Herbaceous habitat at the site included a mixture of grasses, vines, herbs, shrubs, and small trees to 10 feet tall. The dominant grass was Small foxtail (Pennisetum pofystachiori), and the vines were Balsalm Apple (Momordica charantia) and Passiflora suberosa. The Mixed Shrubs included a mixture of trees 3 to 30 feet tall. The dominant small trees in the Mixed Shrub habitat were Tangantangan (Leucaena leucocephald), Sumac (Aidia cochinchinensis), and Sea Hibiscus (Hibiscus tiliaceus).

The flora at Site 19 includes approximately 65 percent of Grassland and Tangantangan forest and 35 percent of Mixed Shrubs (Figure 2-8). Grassland and Tangantangan forest at Site 19 included a mixture of grasses, vines, herbs, shrubs, and small trees to 10 feet tall, which dominate the habitat. The dominant grass was Small foxtail (Pennisetum polystachiori); the dominant vine was Passiflora suberosa; the dominant herb was Dwarf Poinsettia (Euphorbia cyathopord); and

Final Record of Decision 2-2 July 2002 Harmon Annex Operable Unit

the dominant small trees were Tangantangan (Leucaena leucocephald). The Mixed Shrubs included vines and herbs to 10 feet tall, which dominate the habitat (Figure 2-8). The dominant vine was Passiflora suberosa; the dominant herb was False Verbena (Sida sp.); the trees were Tangantangan (Leucaena leucocephald) and Sea Hibiscus (Hibiscus tiliacae). Additionally, other vines, epiphytes, herbs, shrubs, and several small trees were present in small percentages at the site.

The flora at Site 39 includes approximately 35 percent of Grassland habitat and 65 percent of Mixed Shrubs habitat (Figure 2-9). Grassland habitat included a mixture of grasses, vines, herbs, and shrubs up to 3 feet tall. Small trees 3 to 10 feet tall dominate the habitat. The dominant grass was Small foxtail (Pennisetum polystachion) and Wildcane (Saccharum spontaneum), with a mixture of other vines, herbs, shrubs, and small trees. The Mixed Shrubs included vines and herbs up to 3 feet tall; trees 3 to 10 feet tall dominate this habitat. The dominant herb was False Verbena (Sida sp.) and the dominant trees were Sea Hibiscus (Hibiscus tiliacae), Tangantangan (Leucaena leucocephald), and False Elder (Premna obtusifolid). This habitat also had a number of large dead Ifit (Intsia bijugd) trees on the ground. Additional grasses, vines, herbs, shrubs, and trees were present at the site.

The fauna at Sites 18,19, and 39 are similar and include Feral deer (Cervus mariannus), Feral pigs (Sus scrofd), and Feral dogs (Canis familiaris), which migrate across and may inhabit the site. Some bird species observed transiting this habitat were the Black drongo (Dicrurus macrocerus) and Eurasian tree sparrow (Passer montanus).

The population of Guam was projected to be 167,000 by the year 2000, an increase of 26 percent from the total population in 1990 (Guam Annual Economic Review, 1999). Guam is also the most populated island in the Mariana Archipelago. A variety of different ethnic groups inhabit Guam including Chamorro (38 percent) and Filipino (23 percent). The total military population on Guam is approximately 13,000 or about 8 percent of the total population. The population of Andersen AFB is approximately 3,800 or about 3 percent of the total population of Guam. Guam's population is relatively young with a median age of about 25 years, as compared with 33 years for the U.S. mainland.

The Harmon Annex area is sparsely populated. Sites 18, 19, and 39 are isolated and unpopulated and are not proximal to residential areas. The nearest populated village is Dededo to the east. Dededo, with 24 percent of the total island population, is currently the largest populated village on Guam (Guam Department of Commerce, 1999).

A large proportion of Guam's population is employed by the public sector. The federal government employs about 8 percent of the total workforce on Guam and GovGuam employs about 21 percent of the total workforce. Employment in the private sector is dominated by Services (23 percent of the total workforce), Retail Trade (19 percent), and Construction (11 percent). Agriculture accounts for less than one percent of total employment (Guam Department of Commerce, 1999).

Final Record of Decision 2-3 July 2002 Harmon Annex Operable Unit

In 1990, GovGuam initiated a comprehensive study to evaluate Guam's water supply and demand. Subsequently, the water supply in Guam was reported at 40 million gallons per day (mgd) between 1985 and 1989, and the water demand is projected at 225 mgd for the year 2010 (Public Utility Agency of Guam, 1992).

Freshwater is drawn from the non-brackish portion of the groundwater lens, which is known as the Northern Guam Lens (NGL). The NGL is a dynamic system and is the major source of potable water in Guam. The groundwater flow direction in the NGL at Harmon Annex is generally toward the coastline. The important factors governing the amount of freshwater in the lens are the effects of mixing freshwater and seawater, the permeability of the limestone formations, and the rate of recharge (Ward et al., 1965).

Since the mid-1990s, Guam's dependency on groundwater as a drinking source has increased about 80 percent (GEPA, 1997). According to the Water and Environmental Research Institute of the Western Pacific, there are 172 production wells on Guam with an estimated average production rate of 37 mgd. Of these wells, Guam Waterworks Authority (GWA) maintains 109, Andersen AFB maintains 10, and the United States Navy (USN) maintains 13.

Only one production well, H-l, is operating in the Harmon Annex area. Well H-l supplies the nearby treatment plant and a few residences and small businesses with a production rate of 200 gallons per minute (GWA, 1999). Another production well, NCS-5, was operated by the USN, but is currently not in operation (Figure 2-3).

2.2 Site History and Enforcement Activities

The Harmon Annex was originally developed by the USAF in the mid-1940s and generally was used for housing and administration facilities. The major development of the Harmon Annex occurred on the southern portion near the cliffiine, Harmon Village, and the Harmon Cliffline Housing (Figure 2-3). Portions of Harmon Annex were used by the 1958th Communication Squadron for the USAF until 1976, and since then the site has not been used (EA, 1997). Other portions of the Harmon Annex were not developed by the USAF (ICF Technology, 1995).

During World War II (WWII), the USN controlled all property on Guam. In May 1960 under the terms of the Organic Act of 1950, Harmon Annex was formally transferred from the USN to the USAF.

In 1976, Harmon Annex was declared excess land to the USAF mission on Guam and in 1994, Harmon Annex was included in United States Public Law (P.L.) 103-339 for transfer to the GovGuam through the U.S. General Services Administration (GSA). The USAF requires an Environmental Baseline Survey (EBS) for all Air Force-owned property scheduled for real estate transactions. The EBS is generally divided into two phases. The Phase I EBS includes a comprehensive review of available records followed by site reconnaissance to identify areas of concern (AOCs) suspected of potential contamination. Subsequently, the Phase II EBS assesses the AOCs using sampling and analysis to determine the existence of potential contamination.

Final Record of Decision 2-4 July 2002 Harmon Annex Operable Unit Between 1995 and 1997, Phase I and II EBS investigations were conducted at 15 AOCs at the Harmon Annex and seven sites required cleanup (EA, 1997). At these seven AOCs, surface and subsurface samples were collected from abandoned cesspools, open pits, oil/water separators, and waste piles. Based on laboratory analytical results, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, antimony, lead, and/or benzo(a) pyrene were detected in soil samples collected from these accumulation points at concentrations that exceeded the Residential PRGs (EA, 1997). Subsequently, in 1998, material from the cesspools, open pits, oil/water separators, contaminated waste piles, and suspected asbestos-containing material were removed from the seven AOCs and transferred to the Andersen AFB Landfill for disposal. The features were backfilled to grade with clean material. Confirmation soil sampling and analyses at the seven AOCs indicated that all impacted soils were removed such that the analytical results were below Residential PRGs (IT/OHM, 1999a).

Furthermore, due to the primary mission in national defense, the USAF has long been engaged in a wide variety of operations that involve the use, storage, and disposal of hazardous materials. On 14 October 1992, the USEPA Region IX formally listed Andersen AFB on the National Priorities List to investigate the abandoned sites, which may have been impacted by the use, storage, and disposal of hazardous materials. The Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) identification number for Andersen AFB is GU6571999519.

Consequently, the USAF entered into a Federal Facility Agreement (FFA) with the USEPA Region IX and GEPA. The FFA, finalized on 30 March 1993, established a framework for performing detailed environmental investigations (such as the RI) at Andersen AFB. The FFA was based on applicable environmental laws including CERCLA, HSWA, SARA, and the NCP.

In 1986, the USAF used the United States Army's established IRP as a model to implement the FFA. Under the 14 August 1981 Executive Order 12316, the Department of Defense designed their own IRP to identify uncontrolled hazardous waste disposal sites. IRP remedial goals and objectives evolved over the years in a manner consistent with the transformation of environmental laws, such as the 1990 NCP established by CERCLA and SARA (ICF Technology, 1996a).

The mandates of SARA expanded the scope and requirements of CERCLA and provided specific directives to federal facilities regarding the investigation of waste disposal sites. Under SARA, technologies that involve the permanent removal or destruction of hazardous wastes or contaminants are preferable to actions that only contain or isolate the contaminant. SARA also provided greater interaction with public and state agencies and extended the role of the USEPA in the evaluation of the health risks associated with the contamination. Under SARA, an early determination of Applicable or Relevant and Appropriate Requirements (ARARs) is required, and potential remedial alternatives should be considered at the initial phase of an RI. In response to these changes, the IRP also was changed.

The early United States Army IRP was comprised of four phases:

Final Record of Decision 2-5 July 2002 Harmon Annex Operable Unit • Phase I - Initial Assessment/Records Search. This phase identifies the past waste disposal sites that might be impacted by the presence of hazardous materials.

• Phase II - Confirmation/Quantification Study. Using field investigations, including sampling and analysis, this phase identifies the type and the extent of the contamination at a site.

• Phase III - Technology Base Development. This phase identifies the potential remedial alternatives to address the source of contamination at a site.

• Phase IV - Remedial Action. In this phase, the selected remedial alternatives for a site are implemented.

In 1988, the phased IRP approach was superseded by a method that approximates the RI guidelines used by the USEPA. The revised IRP format combined Phase II and Phase TV and more closely paralleled the RI process. This IRP modification provided the USAF the means to select appropriate remedial actions effectively.

IRP investigations at Andersen AFB were initiated in 1983 with a records search to identify the potential sites of concern. As the result of the records search, 20 sites were initially identified as IRP sites of concern, including Site 18 and Site 19. Site 39 was later added as an IRP site when debris was discovered during an excavation in 1989 (ICF Technology, 1996b). In August 1992, a site visit was also conducted at each site to evaluate any potential adverse environmental impacts from past waste disposal practices at Andersen AFB.

2.3 Highlights of Community Participation

In August 1992, to inform and involve the local community, Andersen AFB conducted 67 interviews with local government officials, residents, and concerned citizens to determine the level of community concern and interest in the environmental investigations. These community interviews provided the basis for the 1993 Community Relations Plan (CRP) (ICF Technology, 1993). The 1993 CRP described activities to keep the nearby communities informed of the progress of the environmental investigations at Andersen AFB sites and provide opportunities for input from residents regarding cleanup plans. In response to the USEPA request, Andersen AFB conducted 27 additional interviews in 1998, and updated the CRP (EA, 1998a).

The USAF has promoted community relations and encouraged public involvement in cleanup decisions through the Restoration Advisory Board (RAB), established in 1995. Currently, the RAB is comprised of community members, elected officials, USAF officials, and representatives from regulatory agencies. The RAB meets on a quarterly basis to discuss program progress and to advise the community on the status and plans for the various IRP sites.

In addition to RAB meetings, in 1993 Andersen AFB provided a brochure that was prepared to respond to community concerns and to inform the public about Andersen AFB's IRP investigations (ICF Technology, 1993). In February 1997, a fact sheet for the Harmon Annex was distributed to the community that explained the status of the IRP investigations and the

Final Record of Decision 2-6 July 2002 Harmon Annex Operable Unit status of P.L. 103-339 (EA, 1997). A complete summary of the history and status of community involvement for the IRP at Andersen AFB is presented in the December 2000 Final Management Action Plan (Andersen AFB, 2000).

Andersen AFB also made copies of the Harmon Annex OU reports available to the public in both the Administrative Record and the Information Repository at the following locations:

Installation Restoration Program 36 CES/CEVR, Unit 14007, Andersen AFB, Guam APO AP 96543-4077 Telephone: (671) 366-5080 Contact: Mr. Gregg Ikehara, Installation Project Manager

Nieves M. Flores Memorial Library 254 Martyr Street, Hagatna, Guam 96910 Telephone: (671) 475-4751, 4752, 4753, or 4754 Contact: Christine Scott-Smith

University of Guam Federal Document Department, RFK Library, UOG Station Mangilao, Guam 96923 Telephone: (671) 735-2321 Contact: Walfrid C. Benavente

A notice of the availability for the Harmon Annex OU reports was published in the Guam Pacific Daily News. A notice of this ROD's availability will also be published in the Guam Pacific Daily News after it is signed. A complete Administrative Record Index is presented in Appendix A.

In February 2001, the Proposed Plan for the Harmon Annex OU was released to the public for review and comments, with a public comment period from 06 February to 08 March 2001. A public meeting was held in the Hilton Guam Resort & Spa on 22 February 2001 where the Proposed Plan was presented and representatives from USEPA, GEPA, and Andersen AFB responded to public comments. The results of the public meeting and responses to public comments are presented in Section 3 of this ROD.

2.4 Scope and Role of the Operable Unit or Response Action

Andersen AFB elected to use an OU approach to manage the investigation and remediation of environmental conditions at Harmon Annex. According to the 1993 FFA, the OUs were formed to:

• Expedite the completion of environmental activities

Final Record of Decision 2-7 July 2002 Harmon Annex Operable Unit

• Evaluate sites with similar locations and potentially similar requirements as a group

• Complete remedial design investigations at sites where closure decisions have been previously reached with GovGuam

• Provide a screening mechanism for evaluating newly or tentatively identified sites for inclusion in the Remedial Investigation/Feasibility Study

All environmental investigations at Harmon Annex were performed under the Harmon Annex OU. Until 1996, the soils that were investigated at Harmon Annex were managed under the USAF designation of OU 5, and groundwater as OU 2. In order to concurrently address both soil and groundwater at Harmon Annex, OU 5 and OU 2 were combined into the Harmon Annex OU.

The Harmon Annex OU included three sites (IRP Sites 18, 19, and 39, including the groundwater underlying these sites). Presently, no remedial action is required at any of the three sites of Harmon Annex OU. There is no supporting evidence that Site 18 was ever used as a landfill and no contamination was found at the site. Based on mutual agreement between the USAF, USEPA Region IX, and GEPA, soil removal and off-site land disposal was selected as a cleanup alternative for Sites 19 and 39 to expedite the transfer of Harmon Annex to GovGuam. Subsequently, all sources of contamination were removed from Sites 19 and 39 to prevent current or future exposure to the contaminated soils and prevent potential contaminant migration into the groundwater.

2.5 Site Characteristics

In order to characterize each site, reconnaissance, detailed site inventories, geophysical surveys, soil gas surveys, exploratory test ditches and test pits, surface and subsurface soil sampling, groundwater sampling, drum/sump sampling, and topographical surveys were conducted at the Harmon Annex OU. Because the detailed results of the field investigations are already presented in the Final RI for Harmon Annex OU (EA, 2000), only a summary of fundamental site contaminant characteristics are presented in this ROD.

To evaluate risk associated with each contaminant, laboratory-detected analyte concentrations were compared to PRGs developed by the USEPA Region IX to establish screening criteria for potentially contaminated Residential and/or Industrial sites (USEPA, 1998). Because the future use of Harmon Annex sites is not known, both the Residential and Industrial PRGs are presented in this ROD, when applicable.

In general, the Residential PRGs are established conservatively at lower concentrations as compared with Industrial PRGs. Any analytical results, with the exception of metals, that exceeded the PRGs were further evaluated to assess the potential human health risk associated with each contaminant at a site. Some metal concentrations in Guam soils occur naturally at relatively high concentrations. Background threshold values (BTVs) were established for each metal based on cumulative probability plots of the entire surface soil data set (ICF Technology, 1996a). The data set for each metal was evaluated to distinguish background populations from

Final Record of Decision 2-8 July 2002 Harmon Annex Operable Unit contaminant populations. At the August 2001 Remedial Program Manager (RPM) meeting, USEPA and GEPA requested that BTVs for specific metals (particularly arsenic and manganese) be reviewed using the updated soil analytical database with a consideration for the effects of grain size. A review of the updated database revealed no change in BTV for arsenic (62 milligrams per kilograms [mg/kg]). However, the review resulted in an increase of the BTV for manganese from 3,150 mg/kg to 7,100 mg/kg (EA, 2001).

Subsequently, if any soil sample metal result exceeded the PRG, the result would then be compared with BTVs. The groundwater analytical data collected for the RI were compared with USEPA Safe Drinking Water Act MCLs (USEPA, 1996) and the USEPA Region IX Tap Water PRGs (USEPA, 1998).

2.5.1 Sites 18,19, and 39 Conceptual Model

Conceptual Site Models (CSMs) are useful in assessing the fate and transport of COPCs and evaluating potential exposure pathways relative to present and future receptors, hi order to expedite the property transfer of Harmon Annex sites to GovGuam, the USAF established conservative cleanup standards based on the stringent USEPA Region IX Residential PRGs rather than conducting human and ecological risk assessments. A CSM that is applicable to Sites 18, 19, and 39 is presented in Appendix C.

2.5.2 Site 18 Contaminant Characteristics

Site 18 is located in an undeveloped area of the Harmon Annex. Based on several record searches, site reconnaissance, geophysical survey, 21 test ditch excavations, and 1 passive and 14 active soil gas samples there was no supporting evidence that the site was ever used as a landfill (EA, 2000). No stressed vegetation, stained soil, or fill materials were identified at Site 18 that could be deemed as evidence of waste disposal activities.

The debris identified at the site during the Detailed Site Inventory (DSI) was non-hazardous in nature, such as empty deteriorated drums (Figure 2-10). Scattered Unexploded Ordnance (UXO) identified at the site were removed from the site and disposed of at the Main Base by Air Force Explosive Ordnance Disposal personnel. All UXO found at the site were WWII remnants and typical of UXO found elsewhere on Guam.

Four biased surface soil samples (including one duplicate sample) were collected at Site 18. All surface soil samples were collected from 2.0 to 4.0 inches (0.2 to 0.3 feet) bgs and were analyzed for semivolatile organic compounds (SVOCs) and metals (inorganics).

As presented in Table 2-1, aluminum and chromium were detected in two surface soil samples at concentrations that exceeded the Residential PRGs and BTVs (Figure 2-11). These metal concentrations were close to (within 10 percent) the concentrations of metals established for BTVs and most likely represent background conditions.

Final Record of Decision 2-9 July 2002 Harmon Annex Operable Unit TABLE 2-1. SURFACE SOIL ANALYTICAL RESULTS FOR IRP SITE 18, ANDERSEN AFB, GUAM.

20 Jan 1997 Sample Identification Screening Basis S18S001 S18S002 S18S002DUP S18S004 Analytical 1998 USEPA REGION IX PRGs Sample Depth (feet) Method Analyte | Units BTV Residential Industrial 02-03 02 03 02-03 02 03 SEM I VOLATILE ORGANIC COMPOUNDS SW8270 BENZOIC ACID (ig/kg N/A 100,000,000 nc 100,000,000 nc 720 J <2,400 <2,400 <2,300 SW8270 BIS (2-ETHYLHEXYL) PHTHALATE "g/kg N/A 32,000 nc I40,00d nc <570 350 J <490 <480 INORGANICS SW6010 ALUMINUM mg/kg 173,500 75,000 nc 100,000 nc 190,000 167,000 155,000 200,000 SW6010 ANTIMONY mg/kg 63 30 nc 750 * nc 11 4BN 10 1 BN 82BN 123BN SW60IO ARSENIC mg/kg 62 038 ca 3 ca 31 E 26 2 E 19E 30 3 E SW6010 BARIUM mg/kg 335 5,200 nc 100,000 ^ nc 391 308 259 318

SW6010 BERYLLIUM mg/kg 334 150 nc ^,\f 3400v _ nc 41 36 32 41 SW6010 CADMIUM mg/kg 65 37 nc 930! nc 65 50 47 39 SW6010 CALCIUM mg/kg N/A N/A N/A 25,000 * 38,300 * 55,000 * 7,150* SW6010 CHROMIUM mg/kg 1,080 210 ca 450 ca 1,090 914 806 1,210 SW6010 COBALT mg/kg 29 3,300 nc 29,000 nc 214 184 149 194 SW6010 COPPER mg/kg 722 2,800 nc 70,000 -> nc 79B 58B 2B <084 SW6010 IRON mg/kg * 116,495* 22,000 nc 100,000 nc 120,000 108,000 <575 125,000 SW6010 LEAD mg/kg 166 400 nc 1,000 nc 837 776 665 722 SW6010 MAGNESIUM mg/kg N/A N/A N/A I,430E 1,380E 1,250E 1,050E (l) SW6010 MANGANESE mg/kg 7100 3,100 nc T 45,000 y nc 3,490 2,960 2,820 3,520 SW7471 MERCURY mg/kg 028 22 560 035B 034B 034B 029B SW6010 NICKEL mg/kg 2425 1,500 nc * SA 37,000 " nc 865 862 670 890 SW6010 POTASSIUM mg/kg N/A N/A N/A 96 6 B 123 B 120 B 39 6 B SW6010 SODIUM mg/kg N/A N/A N/A 165 B 155 163 121 B SW7841 THALLIUM mg/kg 142 6 nc "* 150 nc 098* 12* 1 1* 1 7* SW6010 VANADIUM mg/kg 206 520 nc 13,000 nc 147 E 126 F 99 5 E 133 E SW6010 ZINC mg/kg in 22,000 nc ™ 100,000 nc 540 314 233 254 Notes ( 1 ) - Recalculated BTV concentration established m December 200 1 (EA, 2001) BTV = Background Threshold Values, PRG = Preliminary Remediation Goals, E = Reported value is estimated due to the presence of interference, N = Sp.ked sample recovery u not within control limits. * = Duplicate analysis is not B°'d = C«"centrations e1«al ™ «ceed«ther the BTVs or the within control limit, B = Value less than Contract Required Detection Limit, but greater than the Instrument Residential PRGs,, whichever is higher. Detection Limit, ca = Cancer PRG, nc = non-carcinogen, N/A = Not Applicable, mg/kg = milligrams per Bold & Shaded = Concentrations equal or exceed either the BTVs or kilogram, ue/ke= micrograms per kiloeram the Industrial PRGs. whichever is higher.

Final Record of Decision Harmon Annex Operable Unit Page 1 of 1 July 2002

Of the three groundwater monitoring wells at Harmon Annex, well IRP-37 is located near Site 18 (Figure 2-3). Monitoring well IRP-37 was installed during 1996 and has been sampled biannually using a dedicated pump. Based on groundwater monitoring results at IRP-37, groundwater beneath Site 18 is approximately 320 feet bgs and flows westward towards the Philippine Sea. Six groundwater sampling events have been conducted at IRP-37 between fall 1996 and spring 1999. These samples were analyzed for combinations of volatile organic compounds (VOCs), SVOCs, polycyclic aromatic hydrocarbon (PAHs), pesticides/ polychlorinated biphenyls (PCBs), and metals. As presented in Table 2-2, no organic or inorganic compounds were detected at concentrations above MCLs, or PRGs for tap water, with the exception of chloroform and nickel. These compounds were not believed to represent groundwater contamination because chloroform is associated with laboratory contamination and nickel is attributed to corrosion of the stainless steel piston pump and well screen.

2.5.3 Site 19 Contaminant Characteristics

Site 19 is located in an undeveloped area of the Harmon Annex. Based on the records search and site reconnaissance, there was supporting evidence that part of the site was used as a landfill. Debris was disposed in trenches that were later covered with soil.

The debris identified at the site during the DSI included glass bottles, metal banding, rusted sheet metal pieces, piping, wires, deteriorated fire extinguishers, metal containers, engine parts, cables, concrete slabs, steel cables, slag/ash, corrugated metal, suspected asbestos-containing materials, and municipal trash (Figure 2-12). Several 55-gallon drum remnants were identified at the site. With the exception of one drum containing asphalt-like material, the remaining drums were empty and deteriorated. The laboratory analytical results indicated that VOCs were detected in the sample collected from the drum containing asphalt-like materials. The drum was wrapped in plastic and was subsequently disposed of off-island.

A total of 17 surface soil samples (including two duplicates) were collected from Site 19 (Table 2-3 and Figure 2-13). All samples were analyzed for SVOCs and metals. Iron at Parcel B, and antimony, iron, and lead at Parcel C were detected at concentrations that exceeded the Residential PRGs and the BTVs. Most of the iron was detected at concentrations most likely representing background concentrations and therefore no remedial action was recommended in these areas (Figures 2-13 and 2-14). The location of elevated antimony and lead at Parcel C was identified as a "hot spot" and remedial action was recommended (EA, 2000).

A total of 17 subsurface soil samples (including two duplicate samples) were collected at Site 19 (Figure 2-14). For the most part, these samples were analyzed for VOCs, SVOCs, PAHs, metals, and dioxins (using USEPA Method SW8280). As presented in Tables 2-4 and 2-5, at Parcel A, in the fill area on the southwest corner of the site, benzo(a) pyrene, manganese, and dioxins were detected at concentrations above Residential PRGs (Figure 2-14). The initial dioxin subsurface soil samples collected from Site 19 during the RI were analyzed using USEPA Method SW8280. As the Method SW8280 reporting limits (RLs) for individual congeners were above their respective Residential PRGs the data set did not meet data quality objectives. Subsequently, one subsurface soil sample was collected from each of two locations (AAFB04S19S022 and

Final Record of Decision 2-10 July 2002 Harmon Annex Operable Unit TABLE 2-2. GROUNDWATER ANALYTICAL RESULTS FOR MONITORING WELL IRP-37, NEAR IRP SITE 18, ANDERSEN AFB, GUAM.

Sample Identifier Screening Basis IRP-37 IRP-37 IRP-37 IRP-37 IRP-37 IRP-37 Sampling Date 1998 USEPA Region 26-Sep-96 Ol-Apr-97 17-Nov-97 31-Mar-98 02-Nov-98 ll-Apr-99 IX PRGs Method Analyte Units Tap Water MCL VOLATILE ORGANIC COMPOUNDS 8260 CARBON DISULFIDE ug/L 1,040 nc N/A 12J <1 <1 <1 <1 <1 8260 TRICHROLOETHENE (TCE) ug/L 5 F <1 <1 <1 <1 <1 0'7J 8260 CHLOROFORM ug/L 016 ca 100 P 0.5 Jf 0.5 Jt <1 <1 <1 <1 INORGANICS 6010 ALUMINUM Mg/L 36,500 nc N/A <25 76.6 B 109 B 111B 157 B 65 B 6010 ANTIMONY ug/L 15 nc 6 F <2 <2 23B <1 3.6 Bf <1 6010 CALCIUM ug/L N/A 66,700 71,100 68,100 66,200 71,500 67,600 E 6010 CHROMIUM, TOTAL ug/L 100 F 18.4B 44.8 B 40 2 BE 50.4 55.8 627 6010 IRON ug/L 11,000 nc N/A <40 300 123 215 667 256 E 6010 LEAD ug/L 4 nc 15 TT <1 <1 17B 1.1 BN 1.1 BJ 1 BJ 6010 MAGNESIUM ug/L N/A 4,530 5,500 5,000 4,520 5,400 5,010 6010 MANGANESE ug/L 1,700 nc N/A <6 <6 <8 <8 56 <8 6010 NICKEL ug/L 730 nc 100 F <15 112 B 19 B 33.9 B 40.6 45.6 6010 POTASSIUM ug/L N/A 1,390 B 2,350 B 1,360 B 1,6808 1,390 1,110 6010 SELENIUM ug/L 180 nc 50 F 1.2BN <1 <2 <0.7 3.9 B <2 6010 SODIUM ug/L N/A 28,500 33,700 33,200 27,300 30,800 29,100 6010 ZINC ug/L 11,000 nc N/A <12 <12 <12 <12 17.5 B

Final Record of Decision Harmon Annex Operable Unit lofl July 2002

TABLE 2-3. SURFACE SOIL ANALYTICAL RESULTS FOR IRP SITE 19, ANDERSEN AFB, GUAM.

Sample Identiter S19SQ01 S19S002 S19S003 S19S004 S19S005 S19S006 S J 9S007 S 1 9S008 S19S009 Sample Location (Parcel) (A) (A) (A) (A) (A) (A) (B) (B) (B) Sample Depth (feet) Screening Basis 0 2 - 0.3 0.2 - 0.3 0.2 - 0.3 0.2 - 0.3 0.2 - 0.3 0.2 - 0.3 0.2-0.3 02-0.3 0 2 - 0.3 Sample Date 1998 USEPA Region IX PRGs 20-Jan-97 20-Jan-97 20-Jan-97 20-Jan-97 20-Jan-97 20-Jan-97 21-Jan-97 21-Jan-97 21-Jan-97 Method Analyte Units BTV Residential Industrial SEMIVO LATILES SW8270 |BENZO(b)FLUORANTHENE |ng/kg NA 560 3,590 <460 160 J <460 <500 <490 <550 <520 <490 <530 INORGANICS SW60IO ALUMINUM mg/kg 173^00 74,900 nc 100,000 max 111,000 145,000 70,300 130,000 146,000 143,000 135,000 145,000 153,000 SW6010 ANTIMONY mg/kg 63 30.0 nc 749 < nc 7.8 BN 7.4 BN 4.8 BN 9.1 BN 10 BN 10 BN 9.6 BN 9.3, BN 9.2 BN SW60IO ARSENIC mg/kg 62 0.38 ca 2.99 ca 17.8E 15.9E 7.0 30.1 E 30.1 E 32.4 E 16.1 N* 24.8 N* 23.4 N* SW6010 BARIUM mg/kg 335 5,150 nc 4 jMUMMMh max 26.1 31.5 16.2 254 27.5 29.2 25.2 265 30.1 SW6010 BERYLLIUM mg/kg 3,34 150 nc ,' "3,480 /'.'"nc 2.2 2.9 1.3 B 2.5 2.9 3.0 2.5 2.8 3.0 SW6010 CADMIUM mg/kg 6.5 37.5 nc * 934 % ' nc 2.8 6.1 2.2 4.2 4.2 4.2 3.5 3.8 4.0 SW60IO CALCIUM mg/kg N/A N/A N/A 123,000 * 10,800 * 235,000 * 106,000 * 87,900 * 32,400 * 33,700 * 70,300 * 38,500 * SW6010 CHROMIUM mg/kg " 1,080 210 ca 450 ca 598.0 675.0 378.0 695.0 843.0 755.0 812 859 853 SW6010 COBALT mg/kg 29 3,250 nc v; 428,600,''-' nc 13.2 21.9 8.4 15.5 17.5 185 15.5 168 183 SW6010 COPPER mg/kg 72.2 2,780 nc * 69,600 nc 8.0 11.0 8.4 10.3 9.0 6.7 B 91 9.1 45.8 SW6010 IRON mg/kg 116,495 22,500 nc 100,000 max 73,900 85,200 46,500 84,800 97,000 95,200 87,000 95,200 122,000"' SW6010 LEAD mg/kg 166 400 nc ~"' 1,000' nnc 45.2 68.6 73.1 53.4 51.8 645 56.6* 56.3* 57.3* SW6010 MAGNESIUM mg/kg N/A N/A N/A I580E I720E 1900E 1860E 1490 E 1400E 1,310 1,680 E 1.420E ( SW6010 MANGANESE mg/kg 7100 " 3,120 nc '^4530e1Ync 1,900 3,210 1,270 2,150 2,530 2,510 2,830 2,900 3,030 SW7471 MERCURY mg/kg 0.28 22.5 nc • 562 './ire 0.23 B 0.34 B 0.25 B 0.25 B 0.27 B 0.43 B 022B 0.25 B 0.22 B SW60IO NICKEL mg/kg 242.5 1,500 nc 37^00 'nc 52.4 135.0 36.2 71.2 837 75.6 64.3 N 79.8 N 83 .4 N SW6010 POTASSIUM mg/kg N/A N/A N/A 47 B 90.3 B 40.0 B 69.3 B 62.8 139 B 101 81.5 B 152 B SW6010 SELENIUM mg/kg N/A 375 nc " 9370, " nc

Final Record of Decision Harmon Annex Operable Unit Page 1 of2 July 2002

TABLE 2-4. SUBSURFACE SOIL ANALYTICAL RESULTS FOR IRP SITE 19, ANDERSEN AFB, GUAM.

Sample Identiler Sample Location (Parcel) (B) (B) (B) (B) (A) (A) (A) (C) Sample Depth (feet) Screening Basis 45 45 3 2 55 12 Drum @ 5 0 25 Sample Date 1998 USEPA Region IX PRGs 23-Jan-97 23-Jan-97 23-Jan-97 23-Jan-97 27-Jan 97 27-Jan-97 28-Jan-97 29-Jan-97 Method Analyte Units B TV Residential Industrial VOLAT1L ES SW8260 STYRENE Mg/kg N/A 1,700,000 1,700,000 <6 <6 <7 <7 3J <6 <7IO <7 SW8260 M&P XYLENES Mg/kg N/A 320,000 320,000 <6 <6 <7 <7 <6 <6 2,700 JD <7 SW8260 0-XYLENE Mg/kg N/A 280,000 280,000 <6 <6 <7 <7 <6 <6 13,000 D <7 SW8260 ISOPROPYLBENZENE Mg/kg N/A 120,000 » 490,000 <6 <6 <7 <7 <6 <6 1 9,000 D <7 SW8260 N-PROPYLBENZFNE Mg/kg N/A N/A N/A <6 <6 <7 <7 <6 <6 41,000 D <7 SW8260 1 ,3,5-TRIMETHYLBENZENE Hg*g N/A N/A N/A <6 <6 <7 <7 <6 <6 220,000 D <7 SW8260 1 ,2,4-TRIMETHYLBENZENF MS/kg N/A N/A N/A <6 <6 <7 <7 <6 <6 230,000 D <7 SW8260 SEC-BUTYLBENZENE Mg*g N/A N/A N/A <6 <6 <7 <7 <6 <6 12,0000 <7 SW8260 P-ISOPROPYLTOLUENE Mg/kg N/A N/A N/A <6 <6 <7 <7 <6 <6 9,300 D <7 StMlVOLATILES SW8270 PHENANTHRENE Mg/kg N/A N/A N/A <420 <380 <490 <2500 830 <410 <9400 <480 SW8270 FLUORANTHENE Mg/kg N/A 2,000,000 37,400,000 <420 <380 <490 <2500 630 J <410 <9400 <480 SW8270 PYRENE Mg/kg N/A 1,480,000 ,.26,500,000 " <420 <380 <490 <2500 670 J <410 <9400 <480 SW8270 BUTYLBENZYLPHTHALATE Mg/kg N/A 930,000 '930,000 * <420 <380 <490 <2500 260 J <410 <9400 <480 SW8270 DI-N-BUTYL PHTHALATE Mg*g N/A N/A N/A NS NS NS NS NS NS NS NS SW8270 BENZ (A) ANTHRACENE Mg/kg N/A 560 I 3390* <420 <380 <490 <2500 190 J <410 <9400 <480 SW8270 BIS (2-ETHYLHEXYL) PHTHALATE Mg/kg N/A 32,000 ~ tJ4fl,000* - 560 <380 <490 <2500 <770 <410 <9400 <480 SW8270 CHRYSENE Mg*g N/A 55,700 -' 359,000 ' , <420 <380 <490 <250Q 250 J <410 <9400 <480 SW8270 BENZO (B) FLUORANTHENE Mg/kg N/A 560 ,3.590' ^ <420 <380 <490 <2500 270 J <410 <9400 <480 SW8270 BENZO[K]FLUORANTHENE Mg/kg 6100 5,570 *^35,900 <500 <500 <500 <500 <500 <500 <500 <500 SW8270 BENZO (A) PYRENE Mg/kg N/A 56 N 360 <51 <47 <60 <300 210 <49 <1100 <58 PAHs SW8310 |ANTHRACEN E Mg/kg N/A ~ 14,000,000 220,000,000 NS NS NS NS NS NS NS NS SW8310 PLUORANTHENE Mg/kg N/A 2,000,000 f 37,40UOOO NS NS NS NS NS NS NS NS SW8310 PYRENE Mg/kg N/A 1,480,000 * 26,500,000 NS NS NS NS NS NS NS NS SW8310 BENZ(A)ANTHRACENE Mg/kg N/A 560 k 3,590 NS NS NS NS NS NS NS NS SW8310 CHRYSENE Mg*g N/A 32,000 > i4o;ooo * NS NS NS NS NS NS NS NS SW8310 BENZO (B) FLUORANTHENE Mg/kg N/A 560 • ,3^590 NS NS NS NS NS NS NS NS SW8310 BENZO (K) FLUORANTHENE Mg/kg N/A 5,570 35,900 NS NS NS NS NS NS NS NS SW8310 BENZO (A) PYRENE Mg*g N/A 56 ' 360 ' ' NS NS NS NS NS NS NS NS SW8310 DIBENZ (A,H) ANTHRACENE Mg/kg N/A 56 ' 360 NS NS NS NS NS NS NS NS SW8310 INDENO (1 ,2,3-CD) PYRENE Mg/kg N/A 560 "** 3600 NS NS NS NS NS NS NS NS INORGANICS ~~| SW60IO ALUMINUM mg/kg 173^00 ' 74,900 nc 100,000 max 94,300 E 24,400 E 1 50,000 E 182,000 E 25,200 E 37,000 E 37,400 E 212,000* SW6010 ANTIMONY mg/kg 63 300 nc " 749 nc 90 BEN 24 6 EN 10 4 BEN 12 2 BEN 3 1BEN 14 8 BEN 3 4 BEN 121 BN SW6010 ARSENIC mg/kg 62 0 38 ca* 299 ca 76N* 70N* 90BN* 11 9N* 27BN* 55N* 70N* <57 SW60IO BARIUM mg/kg 335 5,150 nc 100,000 t max 176 122 263 347 10 8 B 21 1 140 149 SW6010 BERYLLIUM mg/kg 334 150 nc 3,400 „ nc 1 9 04 29 38 041 065 075 45 SW6010 CADMIUM mg/kg 65 37.5 nc 934 nc 26E 1 1 E 27E 40E 081E 170E 1 1 E 40 SW6010 CALCIUM mg/kg N/A N/A N/A 149,000 309,000 101,000 8,690 309,000 291,000 207,000 3160B

Final Record of Decision Harmon Annex Operable Unit Page 1 of4 July 2002 TABLE 2-4. SUBSURFACE SOIL ANALYTICAL RESULTS FOR IRP SITE 19, ANDERSEN AFB, GUAM.

Sample Identiter S19S026 S19S027 S 1 9S028 SI9S034 Sample Location (Parcel) (C) (C) duplicate (A) (A) duplicate (B) (B) (B) Sample Depth (feet) Screening Basis 1 5 5 sample of 10 10 sample of 5 1 5 15 Sample Date 1998 USEPA Region IX PRGs 29-Jan-97 29 Jan-97 S19S027 28 Oct 97 28 Oct-97 S19S030 29 Oct-97 29 Oct 97 29-Oct-97 Method | Analyte Units BTV Residential Industrial VOLAT1LES SW8260 STYRENE Mg/kg N/A 1,700,000 1,700,000 <7 <7 <7 <8 <7 <7 NS NS NS SW8260 M&PXYLENES Mg/kg N/A 320,000 320,000 <7 <7 <7 <8 <7 <7 NS NS NS SW8260 0-XYLENE MS/kg N/A 280,000 280,000 <7 <7 <7 <8 <7 <7 NS NS NS SW8260 ISOPROPYLBENZENE Mg/kg N/A 120,000 490,000 <7 <7 <7 <8 <7 <7 NS NS NS SW8260 N-PROPYLBENZENE Mg/kg N/A N/A N/A <7 <7 <7 <8 <7 <7 NS NS NS SW8260 1 ,3,5-TRIMETHYLBENZENE Mg*g N/A N/A N/A <7 <7 <7 <8 <7 <7 NS NS NS SW8260 1 ,2,4-TRIMETHYLBENZFNE Mg/kg N/A N/A N/A <7 <7 <7 <8 <7 <7 NS NS NS SW8260 SEC-BUTYLBENZENE Mg/kg N/A N/A N/A <7 <7 <7 <8 <7 <7 NS NS NS SW8260 P-ISOPROPYLTOLUENE MS/kg N/A N/A N/A <7 <7 <7 <8 <7 <7 NS NS NS SEMIVOLATILES SW8270 PHENANTHRENE Mg/kg N/A N/A N/A <450 <470 <470 <500 <460 <460 NS NS NS SW8270 FLUORANTHENE Mg/kg N/A 2,000,000 37,400,000 <450 <470 <470 <500 370 J <460 NS NS NS SW8270 PYRENE Mg/kg N/A 1,480,000 26,500,000 <450 <470 <470 <500 400 J <460 NS NS NS SW8270 BUTYLBENZYLPHTHALATE Mg/kg N/A 930,000 930,000 <450 <470 <470 <500 <460 <460 NS NS NS SW8270 PI-N-BUTYL PHTHALA FE Mg/kg N/A N/A N/A NS NS NS 110J <460 <460 NS NS NS SW8270 BENZ (A) ANTHRACENE Mg/kg N/A 560 3390 <450 <470 <470 <500 <460 <460 NS NS NS SW8270 BIS (2-ETHYLHEXYL) PHTHALATE Mg*g N/A 32,000 „*' 140,000 I <450 <470 <470 190 J <460 <460 NS NS NS SW8270 CHRYSENE Mg/kg N/A 55,700 359,000* <450 <470 <470 <500 350 J <460 NS NS NS SW8270 BENZO (B) FLUORANTHENE Mg*g N/A 560 33M <450 <470 <470 <500 330 J <460 NS NS NS SW8270 BENZO[K]FLUORANTHENE Mg/kg 6100 5,570 ,35,900, - <500 <500 <500 100 J <460 <460 NS NS NS SW8270 BENZO (A) PYRENE Mg/kg N/A 56 360 <54 <57 <57 <61 140 <56 NS NS NS PAHs SW8310 ANTHRACENE Mg/kg N/A 14,000,000 220,000,000 NS NS NS <76 <69 <69 <64 <65 <69 SW8310 FLUORANTHENE Mg/kg N/A 2,000,000 " 37,400,000* NS NS NS <110 <97 <97 <90 <91 <97 SW8310 PYRENE Mg*g N/A 1,480,000 '' 26,500,000 NS NS NS <140 <130

Final Record of Decision Harmon Annex Operable Unit Page 3 of4 July 2002 TABLE 2-5. SUBSURFACE SOIL DIOXIN RESULTS FOR IRP SITE 19, ANDERSEN AFB, GUAM.

Sample Identifer S19S019 S19S022 S19S023 S19S029 S19S030 Sample Location (Parcel) (B) (A) (A) (A) (A) Sample Depth (feet) 4.5 5.5 12 11 11 Sample Date Screening Basis 1/23/97 1/27/97 1/27/97 10/28/97 10/28/97 TEQ* TEQ* TEQ* TEQ* TEQ* 1998 USEPA 1998 USEPA (detect) (detect) (detect) (detect) (detect) WHO Region IX PRG Region IX PRG Cone./ or (0.5 Cone/ or (0.5 Cone./ or (0.5 Cone/ or (0.5 Cone./ or (0.5 Method Analyte Units TEFs Residental Industrial MDL ND) MDL ND) MDL ND) MDL ND) MDL ND) SW8280 2,3,7,8-TCDD Mg/kg 1 0.0038 ca 0.030 ca <0.122 0061 NA <0.127 0064 <0.2 0 100 <0.1 0.050 SW8280 1, 2,3,7 ,8-PeCDD Mg/kg 1 O.682 0.341 NA <071 0355 <0.9 0.450 <0.8 0.400 SW8280 1,2,3,4,7,8-HxCDD Mg/kg O.I <0.475 0 238 NA <0.495 0.248 <0.6 0.300 <0.6 0.300 SW8280 1,2,3,6,7,8-HxCDD Mg/kg 0.1 <0.426 0.213 NA <0.444 0 222 <0.5 0.250 <0.5 0.250 SW8280 1,2,3,7,8,9-HxCDD Mg/kg 0.1 <0.365 0.183 NA <0.38 0 190

Bold & Shsded - Concentrations equal <* ex&ed either the BTV* Of the Industrial PRGs, whichever NA = Not Ana|yzed ishieher. " ' ' * " "" * >- * NS = Not Sampled

Final Record of Decision Harmon Annex Operable Unit Page 1 of2 July 2002 AAFB04S19S023) in Parcel A. These subsurface samples were analyzed for dioxins using Method SW8290. As presented in Table 2-5, Method SW8290 provided significantly lower RLs than Method SW8280. Sample AAFB04S10S023, as analyzed by Method SW8290, also included dioxins at concentrations above Residential PRGs. However, in accordance with an agreement between the USAF, GEPA, and the USEPA Region IX, the subsurface dioxin cleanup standard was established at 1.0 microgram per kilogram (µg/kg) and no cleanup was recommended for dioxins at Parcel A (IT/OHM, 1999b).

As presented in Tables 2-4 and 2-5, three subsurface soil samples and a duplicate soil sample were collected from between 10 and 14 feet bgs, in the southwest corner fill area of Parcel A (Figure 2-14). Benzo(a) pyrene (SVOCs by USEPA Method SW8270) was detected in a single sample (AAFB04S19S030 at 140 µg/kg) at a concentration that exceeded 1he Residential PRG (56 µg/kg), but less than the Industrial PRG (360 µg/kg). This result was considered suspect as benzo(a) pyrene was not detected in the same sample using the more accurate USEPA Method SW8310, and benzo(a) pyrene was not detected in the duplicate sample (AAFB04S19S031D) using either Method SW8270 or SW8310. Manganese was detected in a single sample (AAFB04S19S023 at 7,090 mg/kg) at a concentration that exceeded the Residential PRG (3,120 mg/kg). However, this manganese concentration is just below the revised BTV of 7,100 mg/kg (EA, 2001). Total dioxin (Toxicity Equivalent Quotient [TEQ] by USEPA Method SW8290) was detected in subsurface soil sample AAFB04S19S023 (0.0164 µg/kg) at concentrations exceeding the Residential PRG (0.0038 µg/kg), but less than the Industrial PRG (0.03 µg/kg). This TEQ concentration is considerably lower than the subsurface dioxin cleanup standard of 1.0 µg/kg established by the USAF, GEPA, and the Office of Solid Waste and Emergency Response (OSWER) directive (IT/OHM, 1999c), and no further action is required. Therefore, the area on the southwest corner of Parcel A was not recommended for remediation.

Also at Parcel A, in the vicinity of the nine drums on the northern portion of the parcel, benzo(a) pyrene was detected at a concentration exceeding the Residential PRG (Table 2-4 and Figure 2-14). The drums in the surrounding few feet of soil were marked in the field as a " hot spot" for cleanup (EA, 1998b). One sample was collected from the asphalt-like material in the drum near grid cells F5 and G5. A flame ionization detector reading of 600 parts per million from the drum was recorded in the field. Sample S19S024 was collected from soil/rags inside of the drum and analyzed for VOCs, SVOCs, and metals. As presented in Table 2-4 and Figure 2-14, no SVOCs or metals were detected in the sample collected from the drum content at concentrations that exceeded the Residential PRGs. However, VOCs (for which no Residential or Industrial PRGs are available) were detected in the sample collected from drum content. This drum was wrapped in plastic and was subsequently disposed of off-island.

At Parcel B, aluminum, chromium, and iron were detected in a subsurface soil sample collected in the southern portion of the parcel at concentrations slightly greater than BTVs (Table 2-4). These metal concentrations most likely represent background concentrations and therefore no remedial action was recommended in these areas (Figures 2-13 and 2-14). The subsurface fill area on the northern portion of Parcel B also included samples with dioxins at concentrations above the Residential PRG. As mentioned earlier, USEPA Method SW8280 was used for dioxin analysis during the initial subsurface soil sampling at Site 19. To compare the dioxin sample

Final Record of Decision 2-11 July 2002 Harmon Annex Operable Unit TABLE 2-6. GROUNDWATER ANALYTICAL RESULTS FOR MONITORING WELL IRP-38, NEAR IRP SITE 19, ANDERSEN AFB, GUAM.

Sample Identifier Screening Basis IRP-38 IRP-38 IRP-38 IRP-38 IRP-38 IRP-38 IRP-38 Dup

Sampling Date 1998 USEPA Region IX 25-Sep-96 12-May-97 13-Oct-97 31-Mar-98 03-Nov-98 05-Apr-99 05-Apr-99 PRGs Method Analyte Units Tap Water MCLs VOLATILE ORGANIC COMPOUNDS 8260 CARBON DISULFIDE ug/L 1,040 nc N/A 2t <1 <1 <1 <1 <1 <1 8260 METHYLENE CHLORIDE ug/L 4.3 ca N/A <1 <1

Final Record of Decision Harmon Annex Operable Unit Page 1 of 1 July 2002

A total of 15 surface soil samples (including two duplicate samples) were collected in areas of suspected contamination at Site 39 (Figure 2-16). The surface soil samples were collected during three rounds of sampling. During the first round of sampling in January 1997, surface soil samples were analyzed for SVOCs, metals, and dioxins (using USEPA Method SW8280). During the second round of sampling in October 1997, surface soil samples were analyzed for PAHs (USEPA Method SW8310) and dioxins (USEPA Method SW8280). In May 1998, additional surface soil samples were analyzed for dioxins using USEPA Method SW8290. Dioxin samples were collected in areas where burnt materials were found during test trench and test pit excavations.

A total of 19 subsurface soil samples (including two duplicate samples) were collected during two rounds of sampling (Figure 2-17) similar to surface soil sampling. During the first round of sampling in January and February 1997, subsurface soil samples were analyzed for VOCs, SVOCs, metals, Total Kjeldahl Nitrogen, total phosphorus, and Total Organic Carbon. Based on analytical laboratory results, detection limits for SVOCs and PAHs were elevated due to soil matrix interference. The USAF submitted a variance to include USEPA Method SW8310 for PAH analysis to improve soil detection limits. During the second round of sampling in October 1997, subsurface soil samples were analyzed for PAHs and dioxins using USEPA Method SW8280.

The surface and subsurface soil sample analytical results indicated that there were several impacted areas at Site 39 (Tables 2-7 and 2-8). Three surface soil samples (S39S034, S39S031, and S39S024) near grid cells E6, A6, and C2 were impacted by benzo(a) pyrene at concentrations exceeding the Residential PRGs. Duplicate subsurface sample S39S012dup was impacted by lead at a concentration exceeding the Residential PRG. However, lead was not detected in the associated sample (S39S012) at a concentration exceeding the Residential PRG. The tar/asphalt buried drum area near grid cells F3 and F4 was impacted with SVOCs and PAHs (S39S004, S39S004dup, S39S009, S39S015, and S39S029). Because the property is excess land that is scheduled for transfer to GovGuam, the USAF proposed remedial action for the PAH and SVOC hot spots. The remedial action included the area where the buried drums were observed and the area near grid cells C3 and C4 where buried containers of tar-like material were found. Additionally, no VOCs were detected in any of the subsurface samples collected at Site 39. Subsurface sample S39S017 located north of the stormwater outfall contained detectable PAHs. Even though those detectable PAH constituents were below action standards, the concentration of benzo(a) pyrene was near the Residential PRG.

The oil/water separator's sludge contained VOCs, SVOCs, pesticides, and metals at concentrations above Residential PRGs (Table 2-9). The oil/water separator's floating petroleum product contained an elevated concentration of Total Petroleum Hydrocarbons (TPH) and the liquid contained metals at concentrations above MCLs (Table 2-10). The Air Force recommended the removal of the oil/water separator and liquids (EA, 1998c).

Dioxin was detected in surface and subsurface soil samples collected at Site 39 at concentrations exceeding the Residential or Industrial PRGs (Tables 2-11 and 2-12). Although the majority of dioxin sample results were biased due to high laboratory detection limits associated with the

Final Record of Decision 2-13 July 2002 Harmon Annex Operable Unit

dioxin analytical Method SW8280, confirmation samples (using USEPA Method SW8290) verified the presence of dioxin at the site. Due to the ubiquitous presence of dioxins at concentrations greater than Residential PRGs, the remedial action for dioxins was based on risk assessment. Consequently, additional dioxin confirmation samples using USEPA Method SW8290 were collected at Site 39. These sample results, along with risk assessment results are presented in Appendices B and C of this report.

Monitoring well IRP-36, located nearest to Site 39 (Figure 2-3), was installed in 1996 and has been sampled biannually. Based on groundwater monitoring results at IRP-36, groundwater beneath Site 39 is approximately 320 feet bgs and flows westward towards the Philippine Sea. Six rounds of groundwater samples were collected from IRP-36 between fall 1996 and fall 1999 and analyzed for VOCs, SVOCs, PAHs, pesticides, PCBs, and metals.

As presented in Table 2-13, chromium and nickel were detected in some of the samples collected from IRP-36 at concentrations above the MCLs. However, chromium and nickel were not believed to be due to groundwater contamination. The presence of chromium and some nickel is attributed to corrosion of the stainless steel piston pump and stainless steel well screen.

2.6 Summary of Site Risks

As indicated in the previous section of this ROD, to evaluate risk associated with each contaminant, the concentrations of each laboratory-detected analyte were compared to the 1998 PRGs. If the analyte concentrations exceeded the higher of the PRGs and BTVs, those analytes were regarded as constituents of potential concern (COPCs). Subsequent to determining the COPCs, the frequency of occurrence and concentration of each COPC were evaluated. Those COPCs with elevated concentrations (exceeding PRGs) and a high frequency of occurrence were regarded as COCs. Finally, the Remedial Action Objectives (RAOs) were established for medium-specific remediation goals in order to protect human health and the environment (USEPA, 1988). RAOs identify the specific media (soil, water, and air) and exposure pathways (ingestion, inhalation, and dermal contact) that need to be targeted for remediation. RAOs are often expressed in terms of Remedial Goal Objectives (RGOs) to establish cleanup levels and the extent of cleanup.

To expedite the transfer of Harmon Annex sites to GovGuam, the USAF established conservative cleanup standards based on the stringent USEPA Region IX Residential PRGs. An Action Memorandum was developed and soils above the Residential PRGs were removed except for one location, the PAHs at the buried drum area of Site 39. Based on a human health risk assessment, the residual PAH concentrations at the buried drum area resulted in acceptable risks to human health.

2.6.1 Summary of Site 18 Risks

Based on the RI results (EA, 2000), no storage (for greater than one year), release, or disposal of hazardous substances, petroleum products, or their derivatives has occurred at Site 18. Consequently, there are no current or future human health or ecological risks associated with the

Final Record of Decision 2-14 July 2002 Harmon Annex Operable Unit site and remediation is not required at Site 18. Andersen AFB concluded that the "landfill" did not exist at Site 18 and the site was classified as an Area of No Suspected Contamination. In February 1998, a Final Decision Document No Further Response Action Planned (NFRAP) for Site 18 was submitted and approved by the USEPA and GEPA (EA, 1998d).

2.6.2 Summary of Site 19 Risks

The USAF decided to expedite cleanup of the hot spots by time-critical removal and off-site disposal because Site 19 is excess land to be transferred to GovGuam. The USEPA has categorized remedial actions into three types: emergency, time-critical, and non-time-critical. Emergency and time-critical remedial actions respond to releases requiring action within 6 months. Non-time-critical remedial actions respond to releases requiring action that can start later than 6 months after the determination that a response is necessary.

In January 1998, a Draft Site Characterization Summary Report for Site 19 was submitted and removal action was approved by the USEPA and GEPA (EA, 1998b) for the impacted areas at Site 19. The proposed removal areas at Site 19 were comprised of only small portions (less than 1 percent) of the site (Figure 2-18). The RAOs at Site 19 were to clean up:

• Shallow subsurface soil impacted by benzo(a) pyrene at Parcel A, including the drum in which VOCs were detected

• Surface soil impacted with lead and antimony in the central portion of Parcel C (This area included the suspected asbestos-containing transite pipe).

The cleanup of hot spots at Parcels A and C was proposed to protect human health from exposure to COCs. Andersen AFB selected the most stringent cleanup standards, those for Residential PRGs. Because all COCs were removed to meet the Residential PRGs, no risk assessment was necessary. The cleanup standards for Site 19 were:

• 56 µg/kg for soil containing benzo(a) pyrene at Parcel A

• 400 µg/kg and 63 µg/kg for soil containing lead and antimony, respectively, at Parcel C

• removal of transite pipe at Parcel C

If the selected remedial action had not been implemented, actual or potential releases of COCs from Site 19 might have presented an imminent and substantial impact to public health, welfare, or the environment. The remedial actions were completed in June 1999 and included the excavation, removal, and disposal of waste materials and impacted soil at Site 19.

In March 1998, an Action Memorandum was prepared for the site including the above-referenced removal actions. The March 1998 Action Memorandum was approved by the USEPA and the GEPA. The extent of excavation was based on confirmation soil sample analytical results. After the completion of remedial actions, Site 19 was restored by backfilling

Final Record of Decision 2-15 July 2002 Harmon Annex Operable Unit

the excavation pits using compacted clean fill materials. The sites were graded, but not to their original topography. Therefore, the amount of excavated material did not equal the amount of fill material.

In December 1998, the cleanup of Parcel A began by clearing and grubbing the areas to be excavated (Figure 2-19). A total of nine 55-gallon drums were excavated. Seven of the nine 55-gallon drums were empty and deteriorated. These drums and other metal debris at the site were transported to the Andersen AFB Landfill for disposal (Table 2-14). One drum of asphalt was transported to IRP Site 35/Waste Pile 1, near Andersen AFB Landfill, for asphalt recycling. Another drum, with approximately 25 gallons of liquid, was consolidated and transported to the U.S. mainland for disposal as hazardous materials (IT/OHM, 1999b).

After the disposal of drums and debris, approximately 36 cubic yards (CY) of soil were excavated and stockpiled at the site. One six-point composite confirmation sample was collected at 6 feet bgs. One four-point composite sample was also collected from the stockpiled soil. These soil samples were analyzed for VOCs, PAHs, and SVOCs. As presented in Appendix B, no COCs were detected in either sample at concentrations exceeding the cleanup standards. Subsequently, the excavation pit was backfilled with the stockpiled soil and other site fill materials. The backfilled area was graded and compacted to 85 percent of the maximum dry density (IT/OHM, 1999b).

Between February and April 1999, after clearing and grubbing at Parcel C, approximately 1,400 CY of soil were excavated and stockpiled at the site (Table 2-14). A total of 34 discrete confirmation samples (including three duplicate samples) were collected at depths ranging from 2.5 to 5 feet bgs. Additionally, 17 composite samples (including one duplicate sample) were collected from the stockpiled soil (Table 2-14).

The excavation at Parcel C was completed in two stages. At the end of the first stage, three of 22 confirmation samples collected from the excavation pit had lead concentrations that exceeded the cleanup standards. Consequently, the second stage of excavation was continued and 12 additional confirmation samples were collected until the results of the confirmation samples indicated that all impacted soil had been removed from the excavation pit (Appendix B).

Based on analytical results from 17 confirmation samples collected from the stockpiled soil, approximately 970 CY had acceptable lead and antimony concentrations. However, 530 CY of soil had lead concentrations exceeding the cleanup standards (Appendix B). The 530 CY of lead-impacted soil were transported to the Andersen AFB Landfill for disposal (Table 2-14). The excavation pit was then backfilled with the 970 CY stockpiled soil mixed with 350 CY of imported fill and 80 CY of clean topsoil from Site 19. The amount of excavated material exceeded the amount of backfill material and site grade was slightly lower than its original topography. The backfilled area was graded and compacted to 85 percent of the maximum dry density (IT/OHM, 1999b).

Approximately 4 CY of asbestos-containing transite pipe were removed from Parcel C and transported to the Andersen AFB Landfill for disposal (Table 2-14).

Final Record of Decision 2-16 July 2002 Harmon Annex Operable Unit TABLE 2-14. REMEDIAL ACTION AT AT IRP SITE 19, ANDERSEN AFB, GUAM.

Confirmation Sampling Disposal Sites Backfilling Source Total Excavated Number of Number of Total Backfill Backfill Estimated and Confirmation Clean Number of Number of Andersen using Clean using Backfill On-Site Samples Confirmation Confirmation Clean AFB Landfill Off-Island Portion of Clean Clean Stockpiled from Samples from Samples Confirmation Asphalt Hazardous Stockpiled On-Site Imported Soil Confirmation Excavation Excavation from Samples from Andersen AFB Recycling Disposal Soil Topsoil Fill Remedial Location/COCs (CY) Analysis Pit Pit Stockpile Stockpile Landfill Center Facility (CY) (CY) (CY) Parcel A

VOCs, Seven empty, One 55- One drum with Grid Cell F5/benzo(a)pyrene 36 SVOCs, 1 1 1 1 deteriorated 55- gallon drum 25 gallons of 36 None None PAHs gallon drums of asphalt liquid Parcel C 530 CY of lead- impacted soil and Grid Cell E3/lead and lead and about 4 CY of 1,400 34 31 17 12 None None 970 80 350 antimony antimony asbestos- containing transite pipe Notes COCs = Constituents of Concern, CY = Cubic Yards Duplicate samples are included in the reported number of samples All clean fill materials were supplied using on-tsiand sources All potential hazardous materials were tested before sedmg off-island for disposal Clean portion of stockpile soil = Portion of stockpile with sample results below cleanup standards Clean confirmation samples = All detected analytes were below cleanup standards

Final Record of Decision Harmon Annex Operable Unit Page 1 of 1 July 2002 Control Act, or any other disposal requirements. Upon removal and disposal of the oil/water separator, the cleanup standard for confirmation soil beneath the oil/water separator was established using the Residential PRGs, or risk-based remedial goal options (cleanup standards).

If the selected remedial action had not been implemented, actual or threatened releases of COCs from Site 39 might have presented an imminent and substantial impact to public health, welfare, or the environment. The remedial actions were completed in June 1999 and included the excavation, removal, and disposal of waste materials and impacted soil at Site 39.

In March 1998, an Action Memorandum was prepared for the site including the above-referenced removal actions. The March 1998 Action Memorandum was approved by the USEPA and GEPA. The extent of excavation was based on confirmation of soil sample analytical results. After the completion of remedial actions, the sites were restored by backfilling the excavation pits using compacted clean fill materials. The remedial areas at Site 39 were graded, but not to their original topography. Therefore, the amount of excavated material did not equal the amount of fill material.

As presented in Figure 2-20, the small surface and subsurface benzo(a) pyrene-impacted areas near grid cells E6, A6, C2, and the stormwater outfall required cleanup. The soil beneath the empty buried drum near grid cells F3 and F4 was impacted by benzo(a) pyrene, benz(a) anthracene, benzo(b) fluoranthene, dibenz(a, h) anthracene, and indeno(l, 2,3-cd) pyrene also required cleanup. Finally, the buried tar-like material containers near grid cells C3 and C4 and the oil/water separator and its contents required removal and cleanup.

In May 1998, the removal action for the oil/water separator began by clearing and grubbing the areas around the oil/water separator (Figure 2-21). The liquid, oil/water mixture, and sludge from the oil/water separator were analyzed and determined to contain PCBs. The PCB-impacted liquid, oil/water mixture, and sludge were placed in 175 containers (55-gallon drums) and shipped off-island for disposal as hazardous waste material. The PCB-impacted sediments from the oil/water separator were placed in 36 containers (2,800-pound bulk bags) and shipped off-island for disposal as hazardous waste material. Similarly, the TPH-impacted rinsate water from decontamination of the oil/water separator was placed in 40 containers (55-gallon drums) and shipped off-island for disposal as hazardous waste material. A total of 6,150 gallons of non-hazardous liquid from the oil/water separator and the oil/water chambers were shipped to an on-island facility for disposal and recycling (IT/OHM, 1999c).

After disposal of the oil/water separator and its contents, 846 CY of soil were excavated and stockpiled at the site. A total of 55 composite confirmation samples (including 2 duplicate samples) were collected from beneath the former oil/water separator at depths ranging from 1 to 11 feet bgs. Additionally, one composite sample was collected from the 100 CY of stockpiled soil originating from the excavation of the oil/water separator pipeline. These soil samples were analyzed for PAHs, pesticides/PCBs, total lead, and Total Recoverable Petroleum Hydrocarbons.

The excavation at the location of the oil/water separator was completed in four stages. At the end of the first stage, seven of 21 confirmation samples collected from the excavation pit had

Final Record of Decision 2-18 July 2002 Harmon Annex Operable Unit

PCB concentrations exceeding the cleanup standards. After the second stage of excavation, nine of 22 confirmation samples collected from the excavation pit contained PCBs and pesticides exceeding the cleanup standards. After the third stage of excavation, only one of 11 confirmation samples collected from the excavation pit contained pesticides that exceeded the cleanup standards. Finally, following the fourth stage of excavation, the results of the last confirmation sample indicated that all impacted soil had been removed from the excavation pit (Appendix B).

All 846 CY of the excavated soil from the location of the oil/water separator were transported to Andersen AFB Landfill for disposal (Table 2-15). Based on sample results, 100 CY of stockpiled soil from the oil/water separator pipeline were not impacted by any COC. Subsequently the oil/water separator excavation pit was backfilled with the 100 CY of stockpiled soil mixed with 1,000 CY of imported fill. The backfilled area was then graded and compacted to 85 percent of the maximum dry density (IT/OHM, 1999c).

In September 1998, the remedial action for the small benzo(a) pyrene hot spots near grid cells E6, A6, C2, and the stormwater outfall began (Figure 2-21). After clearing and grubbing, approximately 192 CY of soil were excavated and stockpiled at the site. A total of 19 composite confirmation samples (including two duplicate samples) were collected at depths ranging from 1 to 5 feet bgs. These soil samples were analyzed for PAHs. As presented in Appendix B, with the exception of one final confirmation sample, COCs were detected in all other confirmation samples at concentrations exceeding the cleanup standards. Consequently, all 192 CY of the excavated soil from the hot spots near grid cells E6, A6, C2, and stormwater outfall were transported to Andersen AFB Landfill for disposal (Table 2-15). The excavation pits near grid cells E6, A6, C2, and the stormwater outfall were backfilled with 140 CY of imported fill. The backfilled area was then graded and compacted to 85 percent of the maximum dry density (IT/OHM, 1999c).

In July 1998, the remedial action for the benzo(a) pyrene, benz(a) anthracene, benzo(b) fluoranthene, dibenz(a, h) anthracene, and indeno(l ,2,3-cd) pyrene in soil at the vicinity of the empty buried drum area near grid cells F3 and F4 began (Figure 2-21). After clearing and grubbing, approximately 5,412 CY of soil and 850 containers (55-gallon empty and deteriorated drums) were excavated and stockpiled at the site. A total of 70 composite confirmation samples (including eight duplicate samples) were collected at depths ranging from 1 to 14 feet bgs. These soil samples were analyzed for PAHs. A total of 16 samples were also analyzed for PCBs and eight samples were analyzed for dioxins (Table 2-15).

The excavation at the location of the empty buried drum area was completed in five stages. At the end of the first stage, 15 of 25 confirmation samples collected from the excavation pit had PAHs exceeding the cleanup standards. No PCBs or dioxins were detected in any of the samples analyzed for PCBs/dioxins at concentrations above action standards. After the second stage of excavation, none of the 10 confirmation samples collected from the excavation pit floor contained PAHs exceeding the cleanup standards. The excavation pit floor was confirmed to be clean. The excavation of the walls continued after the third stage, and six of nine confirmation samples collected from the walls of the excavation pit had PAHs exceeding the cleanup standards. After the fourth and fifth stages of excavation only three of 27 confirmation samples,

Final Record of Decision 2-19 July 2002 Harmon Annex Operable Unit TABLE 2-15. REMEDIAL ACTION AT IRP SITE 39, ANDERSEN AFB, GUAM.

Confirmation Sampling Disposal Sites Backfilling Source

Excavated Andersen Backfill Estimated and Total Number of Total Number of AFB On-Island using Clean Backfill On-Site Number of Clean Number of Clean Landfill Nonhazardous Portion of Clean Stockpiled Confirmation Confirmation Confirmation Confirmation Andersen Asphalt Off-Island Disposal and Stockpiled Imported Soil Confirmation Samples from Samples from Samples from Samples from AFB Recycling Hazardous Recycling Soil Fill Remedial Location/COCs (CY) Analysis Excavation Pit Excavation Pit Stockpile Stockpile Landfill Center Disposal Facility Facility (CY) (CY) Buried Tar-Asphalt Container Area 1,416 CY of PAH- 242 CY of impacted VOCs, PAHs, Hsphalt soil, 132 CY 1 Icontainers (55- SVOCs, debris 311 d Grid Cells C3 and of gallon drums) 5,244 PCBs, 13 12 11 9 8(55- None 3,757 1,000 C4/Tar/Asphalt PAH/cresol- with liquid and Pesticides, gallon) impacted solid cresol Dioxin(4) drums of soil, and asphalt • 315CYof metal debris Notes1 COCs = Constituents of Concern; C Y = Cubic Yards 1 = TRPH analysis was performed on the first 2 1 samples only. Duplicate samples are included in the reported number of samples. 2 = Dioxin analysis was also performed on the Stormwater Oufall samples. AH clean fill materials were supplied using on-island sources 3 -* PCB analysis was performed on the first 16 samples and dioxin analysis was performed on the first 7 samples samples only AH potential hazardous materials were tested before seding off-island for disposal. 4 = Dioxin analysis was performed on 3 samples and PAH analysis was performed on the first 5 samples only. Clean portion of stockpile soil = Portion of stockpile with sample results below cleanup standards ^lean confirmation sample results - AH detected analytes were below cleanup standards.

Final Record of Decision Harmon Annex Operable Unit Page 2 of2 July 2002 Based on stockpile sample results, no COCs were detected in nine of 11 stockpiled soil samples and approximately 3,757 CY of the excavated soil were not impacted. Therefore, the excavation pits at the buried tar-asphalt container area near grid cells C3 and C4 were backfilled with a total of 3,757 of excavated soil and 1,000 CY of imported fill. The backfilled area was then graded and compacted to 85 percent of the maximum dry density (IT/OHM, 1999c).

Human health and ecological risk assessments were performed at Site 39 for benzo(a) pyrene, detected at the empty buried drum area near grid cells F3 and F4, and dioxins, detected in surface soil site wide. In addition to benzo(a) pyrene and dioxin as COCs, other COPCs were also considered for the human health and ecological risk assessments.

Conservative and realistic present and future scenarios were used in the evaluation of potential risk to receptors that may be exposed to the site. The selected ecological receptors included representative key trophic level species and generic plants including musk shrew, Norway rat, feral dog, Micronesian starling, and the monitor lizard. Based on risk assessment results, there is negligible ecological risk associated with any of the benzo(a) pyrene, dioxin, and other COPCs at Site 39 (Appendix C).

For the human health risk assessment, cancer and noncancer risks associated with exposure to benzo(a) pyrene, dioxin, and other COPCs were evaluated for hypothetical receptors including groundkeepers, sportsmen, trespassers, and residents. Based on the human health risk assessment, there are no adverse health effects associated with benzo(a) pyrene, dioxin, or any other COPCs at Site 39 (Appendix C).

2.7 Description of No Further Action Alternative

The No Further Action alternative was selected for the Harmon Annex OU because all COCs have been removed from these sites and the sites are already in a protective state posing no current or future risks to human health and the environment.

2.7.1 No Further Action Alternative for Site 18

No storage (for greater than one year), release, or disposal of hazardous substances, petroleum products, or their derivatives has occurred at Site 18. There are no current or future human health or ecological risks associated with the site and remediation is not required at Site 18. Therefore, the No Further Action alternative is proposed for this site.

2.7.2 No Further Action Alternative for Site 19

After removing the COC-impacted soil and debris from Site 19, the statutory requirements of Section 121 of CERCLA were met. Soil removal at Site 19 eliminated site COCs and then-potential exposure to human health and the environment. The implementation of the soil removal did not create any short-term risk, nor any cross-media consequences. Any residual risk remaining at the site to human health and the environment is minimal. The implementation of

Final Record of Decision 2-21 July 2002 Harmon Annex Operable Unit TABLE 2-16. SUMMARY OF PERTINENT ARARs FOR IRP SITES 19 AND 39, ANDERSEN AFB, GUAM.

Act or Authority Requirement Requirement's Impact on Soil Removal and Off-site Disposal

Federal Chemical-Specific ARARs USEPA Region IX Preliminary Screens and establishes Risk-based Cleanup Goals Soils exceeding PRGs were excavated and removed from the site. Remediation Goals (PRGs) for chemicals in soil, air, and water. Federal Insecticide, Fungicide, and Regulates the disposal and storage of pesticides Soils impacted by pesticides were excavated and removed from the Rodenticide ACT (FIFRA) and their containers. site. 60 CFR 32094 Toxic Substances Control ACT (TSCA) Regulates wastes containing PCB constituents. Soils, liquid, sludge, and sediments impacted by PCBs were 60 CFR 761 excavated and removed from the site.

Federal Location-Specific ARARs Endangered Species Act Promotes actions to conserve endangered species All migratory routes for endangered species were examined prior 16 USC 1 53 1 and 50 CFR 200, 402 or habitats. to soil removal and off-site disposal. There were no endangered species, or migratory routes, at or near the site.

Federal Action-Specific ARARs Clean Air Act (CAA) Regulates the air quality against National Ambient Air monitoring plan was established during soil removal action. 40 CFR 50 Air Quality Standards. The dust control measures were implemented using water trucks and spray. Hazardous Materials Transportation Act Regulates the transportation of hazardous waste All excavated impacted soils and hazardous waste materials that (HMTA) materials on national highways in accordance with were disposed of at an off-island landfill were handled in 40 CFR 100-177 Department of Transportation (DOT). accordance with HMTA and DOT.

Territorial (Guam)-Specific ARARs Resource Conservation and Recovery Act Tracks the destiny of hazardous waste from All hazardous waste materials were handled, stored, and (RCRA) "cradle to grave." transported off-site at the Andersen AFB landfill in accordance 40 CFR 261, 262, 263, and 268 with RCRA. Solid Waste Management Act, 10 Guam Regulates solid waste collection and disposal on All solid decontamination wastes (i.e., non-hazardous waste) were Code Annotated (GCA), Chapter 5 1 Guam. transported and disposed at Andersen AFB landfill in accordance with Guam's solid waste management.

Final Record of Decision Page 1 of 1 July 2002 Harmon Annex Operable Unit 3. RESPONSIVENESS SUMMARY

The community response regarding the Harmon Annex OU is an important part of this ROD due to the land transfer issue. In this section, a summary of public involvement and comments are presented.

In an effort to inform and involve the local community, the RAB was established in 1995 comprising community members, elected officials, Air Force officials, and representatives from regulatory agencies. Since 1995, the RAB has regularly held quarterly meetings that were open to the public. During the RAB meetings, the progress of the environmental investigations at Andersen AFB's IRP site was discussed. The RAB served as a major focal point for environmental exchange between Andersen AFB and the local community.

Furthermore, the RI and Proposed Plan for the Harmon Annex OU was released to the public in November 2000 and February 2001, respectively. Later, Andersen AFB published a notice of availability for the RI and Proposed Plan reports regarding the Harmon Annex OU in Guam's Pacific Daily News from 06 through 08 February 2001. The notice also included the dates of public comment period from 06 February to 08 March 2001. A public meeting was held in the Hilton Hotel on 22 February 2001 in Guam where representatives from USEPA, GEPA, and Andersen AFB responded to public inquiries regarding the Proposed Plan for the Harmon Annex OU.

Upon completion of the public comment period, no written comments were received from the public. A transcript of questions and comments generated at the public meeting are presented on the following pages.

Final Record of Decision 3-1 July 2002 Harmon Annex Operable Unit ANDERSEN AIR FORCE BASE HARMON PROPOSED PLAN MEETING MINUTES 22 February 2001

ATTENDEES

Board Members and Support Public

Col. E. Schoeck (AAFB) - Installation Co-chair Mr. J. Iglesias - for Congressman Underwood Mr. C. Crisostomo - Mediator Mr. C. Arnsfield - IT Mr. J. Jocson - RAB Member Mr. Brian Gilkison, IT Mr. M. Gawel - RAB Member Mr. P. Ono - IT Mr. F. Castro - RAB Member Ms. N Acedera - IT Ms. M. Quenga - RAB Member Mr. K. Damiro - BOP Mr. E. Artero - RAB Member Dr. J. Rosacker - UNITEC Ms. J. Duwel - RAB Mr. T. Towers - Weston Mr. T. Quillen - TechLaw for USEPA Mr. J. Floden - UNITEC Mr. W. Leon Guerrero - GEPA Mr. T. Ghofrani - EA Mr. D. W. Longa - GEPA Mr. R. Shambach - EA Ms. G. O. Garces - GEPA Mr. D. Mercadante - EA Mr. L. Richman - GEPA Mr. J. Lazzeri - EA Mr. D. Perez - GEPA Mr. J. Morrell - EA Ms. J. Poland - AAFB Mr. M. Price - EA Capt. O. D. Leff- AAFB Dr. M. Knight - URS Capt. M. Escudie - AAFB Mr. M Bone - Foster Wheeler Mr. J. Torres - AAFB Mr. S. Seyedian - Foster Wheeler Mr. G. Ikehara - AAFB Ms. M. Donahue - Earth Tech Mr. D. Agar - AAFB Mr. D. Griffin - Earth Tech Mr. J. Hill - AFCEE Mr. D. Baxley - Earth Tech Mr. J. Sullivan - PACAF Mr. J. Fern - Earth Tech Mr. G. Fujimoto - PACAF Mr. G. Delson - Earth Tech Ms. T. Torres Mr. C. Herndon - RAG Mr. J. A. Flores - BEI Dr. S. Hewins - Texas A& M University

[Please note that the comments in brackets are added for further clarification]

Introduction:

Mr. G. Ikehara introduced Mr. C. Crisostomo as the meeting mediator. Mr. C. Crisostomo stated that during this portion of the program, the study, cleanup, and the Final Proposed Plan for the three sites at Harmon Annex were to be presented. Mr. C. Crisostomo pointed out that the locations of these sites were indicated on maps located on tripods at the entrance of the meeting room. Writing materials were provided to the public for note taking and/or writing of questions that might come up during the presentation. Additionally, post cards were provided for any written comments that could be submitted later to Andersen AFB by 08 March 2001. Mr. C. Crisostomo then introduced Mr. J. Torres to present the Harmon Proposed Plan.

Final Record of Decision 3-2 July 2002 Harmon Annex Operable Unit At Site 19, metal debris, asbestos containing transite pipe, and 55-gallon drums were identified during the detailed site inventory. Soil samples were collected and dioxin, benzo(a) pyrene, antimony, and lead concentrations exceeded Residential PRGs. Because of the urgency in transferring Harmon Annex, Andersen AFB decided to establish conservative cleanup standards based on the USEPA Region IX Residential PRGs and remove the drums, asbestos piping, and impacted soil from Site 19. About 530 cubic yards of impacted soil (exceeding Residential PRGs), nine 55-gallon drums, and other metal debris were transported to the Andersen AFB Landfill for disposal. About 4 cubic yards of transite pipe was removed from the site and shipped to an off-island hazardous disposal and recycling facility. After removing the impacted soil and conducting confirmation sampling, the excavated areas were backfilled with clean fill.

At Harmon Substation, Site 39, an oil/water separator, tar/asphalt drums, asphalt and metal debris, and electrical power components were identified. Soil samples were collected and benzo(a) pyrene and dioxin concentrations exceeded Residential PRGs. The impacted soil, drums, and debris were removed from Site 39 and transported to the Andersen AFB Landfill for disposal. The excavated areas were then backfilled with clean fill. Also, the oil/water separator with its PCB-impacted contents was removed from Site 39 and transported to an on-island disposal facility. About 7,998 cubic yards of benzo(a) pyrene impacted soil, 850 empty drums, and 315 cubic yards of metal debris were transported to the Andersen AFB Landfill for disposal. Also, 6,150 gallons of non-hazardous liquid from the oil/water separator was transported to an on-island, nonhazardous disposal and recycling facility. A total of 175 drums (55-gallon) with liquid/sludge, 2,800 pounds of PCB-impacted sediments, 40 drums of TPH-impacted liquid, and 1 1 drums of liquid/solid cresol were transported to an off-island hazardous disposal and recycling facility.

Additionally, groundwater monitoring at the Harmon Substation began in 1995 and in 1996 three monitoring wells were installed at Harmon Annex. Based on sampling and monitoring of the wells at Harmon, only nickel and chromium were detected at concentrations above EPA standards. However, nickel and chromium detection is related to premature deterioration of the stainless steel pumps and the well screens.

Mr. J. Torres then summarized his presentation by indicating that the remedial investigation extended from July 1996 to December 1997, followed by cleanup work from May of 1998 to June of 1999. Andersen AFB is now proposing No Further Action for Sites 18, 19, and 39. The final remedial investigation and cleanup reports have all been completed and approved by the USEPA and GEPA, and the Final ROD is expected to be completed by October 2001 after incorporating any public comments. Mr. J. Torres then opened the forum for any questions or comments from public.

Q/A:

1st Question by Mr. E. Artero?: Once the contaminated soils are excavated where do they go?

1st and only response by Mr. J. Torres: That depends on the soil. If soil is tested to be hazardous, it will be shipped off-island. If the soil is non-hazardous waste and meets PRGs

Final Record of Decision 3-4 July 2002 Harmon Annex Operable Unit 9th Question by Ms. T. Torres: What do you mean by No Further Action?

1st and the only response by Mr. G. Ikehara: As Mr. J. Torres explained, No Further Action means that all cleanup actions have already been taken to completion and there is no other human or ecological risk at the site; therefore, no further remediation is needed at the site.

10th Question by Ms. C. Herndon: If any other drum is found at these sites in the future, who will be responsible for the cleanup?

1st and only response by Mr. G. Ikehara: As long as the waste is related to Andersen AFB activities, Andersen AFB will be responsible for the cleanup.

11th Question by Ms. T. Torres: Wouldn't moving of contaminated soil to the Andersen AFB Landfill pose a future problem?

1st and only response by Mr. G. Ikehara: Before moving any soil to Andersen AFB, the soil will be tested to make sure that it is not hazardous. If it is hazardous soil, it will be shipped off-island for disposal. If the soil is not hazardous waste, and below industrial PRGs, it can be transported to the Andersen AFB Landfill for disposal.

2nd and only response by Ms. J. Poland: The impacted soils at Harmon were removed so that these sites are safe for future residential use. When soils are impacted at levels between Residential and Industrial PRGs, they can be safely disposed at the Andersen AFB Landfill. Furthermore, the Andersen AFB Landfill includes a liner that prevents any potential leaching to groundwater. Andersen AFB's Landfill is the only permitted landfill on-island and complies with the most stringent environmental regulations.

At the conclusion of the meeting, Mr. G. Ikehara reiterated that any other questions or comments could be sent to Andersen AFB. There are two repositories where hard copies of the Harmon Proposed Plan are available for public review. The two repositories are the Nieves M. Flores Memorial Library in Hagatna and the Robert F. Kennedy Memorial Library at the University of Guam.

Final Record of Decision 3-6 July 2002 Harmon Annex Operable Unit 4. REGULATORY COMMENTS AND AIR FORCE RESPONSES

In this section of the ROD, all USEPA and GEPA comments will be presented along with the USAF responses. All original USEPA and GEPA comments are presented as received, in reference to the May 2001 Draft Record of Decision for Harmon Annex Operable Unit (Draft ROD). However, the responses are presented in reference to this Final ROD.

Response to USEPA Comments on the May 2001 Draft Record of Decision for Harmon Annex Operable Unit Andersen Air Force Base, Guam

The Draft Record of Decision for Harmon Annex Operable Unit (Draft ROD) was reviewed for completeness and technical adequacy considering historical site information and the USEPA Guidance document Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (ROD Guidance) dated July 1999 (EPA 540-R-98-031, found at http://www.epa.gov/superfund/resources/remedy/rods/).

GENERAL COMMENTS

The ROD should contain an Administrative Record Index for the site.

Response to General Comment. 1; The following sentence will be added to the first paragraph of Page 2-7:

"A complete Administrative Record Index is presented in Appendix A."

The ROD should include a placeholder section for regulatory comments and DOD responses to comments on the ROD.

Response to General Comment 2: The following section will be added to the ROD to include the regulatory comments and USAF responses:

"4. REGULATORY COMMENTS AND AIR FORCE RESPONSES

In this section of the ROD, all USEPA and GEPA comments will be presented along with the USAF responses."

The Air Force should provide more justification in the ROD for not conducting an ecological risk assessment at Site 19.

Response to General Comment 3: A short discussion will be added to Section 2.6.2 as follows:

"An ecological risk assessment was not conducted at Site 19; however, a habitat inventory was conducted that identified grassland and Tangantangan forest containing mostly non-indigenous

Final Record of Decision 4-1 July 2002 Harmon Annex Operable Unit fauna. In addition, no rare, threatened, or endangered species have been observed in the site or vicinity. Given a possible future residential use for the site, the decision was made to perform cleanup using EPA Region IX Residential PRGs as cleanup goals. A comparison of PRGs to the residual COC concentrations and the ecological receptors observed at Site 19 indicated no risk to the human health or the environment."

SPECIFIC COMMENTS

Page 1-1, Title. Please remove the subtitle: "Statutory Preference ... is Not Required". These statements should be within a Statutory Determinations section. Insert a new section, either after 1.3 or after 1.4 that reviews the statutory requirements of CERCLA 121 and the regulatory requirements of the NCP. The applicability of the five-year review should also be in this new section.

Response to Specific Comment 1: The statement "Statutory Preference for Treatment as a Principal Element is Met and Five-Year Site Review is Not Required" will be omitted from the title of the Declaration.

According to the USEPA Interim Final Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The Record of Decision, Explanation of Significant Differences, The Record of Decision Agreement, Report No. OSWER 9335.3-02, Chapter 9, Exhibit 9-2, Statutory Determination is not required for documenting a No Action Decision. Consequently, no Statutory Determination will be added after either Sections 1.3 or 1.4.

Page 1-2, First Paragraph. Replace the word remedial in the first sentence with removal.

Response to Specific Comment 2: The first paragraph of Page 1-2 will be revised to state that:

"This removal action was protective of human health and the environment and complied with federal and territorial (Guam) requirements that were legally applicable or relevant and appropriate."

Page 1-2, First Paragraph. I don't like the phrase "not impacted by the COCs detected in the soils that were eventually removed from Sites 19 and 39". Perhaps change the sentence to " No COCs were detected in the groundwater under the Harmon Annex above (detection limits, background levels or health based action levels, whichever is true)".

Response to Specific Comment 3: The first paragraph of Page 1-2 will be revised to state that:

"No COCs were detected in the groundwater under Harmon Annex above MCLs, or PRGs for tap water, with the exception of chloroform, chromium, and nickel These compounds do not represent groundwater contamination because chloroform is associated with laboratory contamination and chromium and nickel are attributed to corrosion of the stainless steel piston pump and well screen."

Final Record of Decision 4-2 July 2002 Harmon Annex Operable Unit Decision Summary, Section 2.1. The Draft ROD does not identify the National Superfund database identification number (e.g., CERCLIS) for the site. This number helps to identify the site for future information inquiries. Please revise Section 2.1 of the ROD to provide information related to the CERCLIS number for Andersen Air Force Base and, if applicable, the Harmon Annex.

Response to Specific Comment 4: The following sentence will be added at the end of the second paragraph on Page 2-5:

"The Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) identification number for Andersen AFB is GU657] 999519."

Decision Summary, Section 2.2. The second sentence of this paragraph states that "either cesspools, open pits, oil/water separators, or surface debris were suspected as the source of surface soil contamination by COCs...." This language is confusing as the "source" of the constituents of concern (COC) should be an operational process that took place at the Harmon Annex. For example, 4,4'-DDD, 4,4'-DDE, and 4,4'-DDT are listed in the 4th paragraph as COCs and these compounds are pesticides. It seems that the pesticide application process and the area to which the pesticides were applied should be identified as the "source" of these compounds. It is not clear from the text presented in the Draft ROD whether the basins listed above happened to just be accumulation points for these contaminants or whether the areas were in fact the "source" of the COCs. Please revise the Draft ROD to more clearly describe the source of the COCs described in Section 2.2, 4th paragraph.

Response to Specific Comment 5; The fourth paragraph of Section 2.2 will be revised to state that:

"At these seven AOCs, surface and subsurface samples were collected from abandoned cesspools, open pits, oil/water separators, and waste piles. Based on laboratory analytical results, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, antimony, lead, and/or benzo(a) pyrene were detected in soil samples collected from these accumulation points at concentrations that exceeded the Residential PRGs (EA, 1997). Subsequently, in 1998, material from the cesspools, open pits, oil/water separators, contaminated waste piles, and suspected asbestos containing material were removed from the seven AOCs and transferred to the Andersen AFB Landfill for disposal. The features were backfilled to grade with clean material"

Decision Summary, Section 2.2, 4th paragraph. The last sentence of this paragraph mentions "action limits" related to the remediation that took place at the Harmon annex AOCs. The specific action limits that were applied are not specified. This information would be useful for assessing the nature of the remedial activities that took place at the AOCs. Please revise the Draft ROD to specify the action limits that were applied to the Harmon Annex AOC remedial activities. In addition, the Air Force may want to provide information on Guam and EPA Region IX regulatory interaction related to the AOC remedial actions.

Final Record of Decision 4-3 July 2002 Harmon Annex Operable Unit Response to Specific Comment 6: The fourth paragraph of Section 2.2 will be revised to state that:

"Confirmation soil sampling and analyses at the seven AOCs indicated that all impacted soils were removed such that the analytical results were below Residential PRGs (IT/OHM, 1999a)."

Decision Summary, Section 2.3. Section 2.3, Highlights of Community Participation, does not mention a Community Relations Plan for Andersen Air Force Base. Please revise the ROD to reference the Andersen Air Force Base Community Relations Plan, if such a document affected community involvement in the remedial activities that took place at the Harmon Annex.

Response to Specific Comment 7: The first paragraph of Section 2.3 will be revised to state that:

"In August 1992, to inform and involve the local community, Andersen AFB conducted 67 interviews with local government officials, residents, and concerned citizens to determine the level of community concern and interest in the environmental investigations. These community interviews provided the basis for the 1993 Community Relations Plan (CRP) (ICF Technology, 1993). The 1993 CRP described activities to keep the nearby communities informed of the progress of the environmental investigations at Andersen AFB sites and provide opportunities for input from residents regarding cleanup plans. In response to the USEPA request, Andersen AFB conducted 27 additional interviews in 1998, and updated the CRP (EA, 1998).

The USAF has promoted community relations and encouraged public involvement in cleanup decisions through the Restoration Advisory Board (RAB), established in 1995. Currently, the RAB is comprised of community members, elected officials, USAF officials, and representatives from regulatory agencies. The RAB meets on a quarterly basis to discuss program progress and to advise the community on the status and plans for the various IRP sites."

Decision Summary, Section 2.3. Section 2.3, Highlights of Community Participation, does not mention the February 22, 2001 public meeting that took place for the Harmon Annex Operable Unit Proposed Plan. Even though this meeting is discussed in Section 3, Responsiveness Summary, of the Draft ROD, the occurrence of the meeting should also be mentioned in Section 2.3 as it was a significant community participation milestone.

Response to Specific Comment 8: The following paragraph will be added following the last paragraph of Section 2.3:

"In February 2001, the Proposed Plan for the Harmon Annex OU was released to the public for review and comments, with a public comment period from 06 February to 08 March 2001. A public meeting was held in the Guam Hilton Hotel on 22 February 2001 where the Proposed Plan was presented and representatives from USEPA, GEPA, and Andersen AFB responded to public comments. The results of the public meeting and responses to public comments are presented in Section 3 of this ROD."

Final Record of Decision 4-4 July 2002 Harmon Annex Operable Unit Decision Summary, Section 2.5. The third paragraph in Section 2.5, Site Characterization, mentions background threshold values (BTV) that were, established for the Andersen Air Force Base project. The ROD does not provide a reference to additional information regarding the derivation of the BTVs. Please revise Section 2.5 of the ROD to provide a reference for the derivation of the BTVs used during the Harmon Annex remedial activities.

Response to Specific Comment 9; The third paragraph of Section 2.5 will be revised to include a reference to BTVs, as follows:

"Some metal concentrations in Guam soils occur naturally at relatively high concentrations. Background threshold values (BTVs) were established for each metal based on cumulative probability plots of the entire surface soil data set (JCF Technology, 1996). The data set for each metal was evaluated to distinguish background populations from contaminant populations." At the August 2001 Remedial Program Manager (RPM) meeting, USEPA and GEPA requested that BTVs for specific metals (particularly arsenic and manganese) be reviewed using the updated soil analytical database with a consideration for the effects of grain size. A review of the updated database revealed no change in BTV for arsenic (62 mg/kg). However, the review resulted in an increase of the BTV for manganese from 3,150 mg/kg to 7,100 mg/kg (EA, 2001).

Decision Summary, Section 2.5. Section 2.5, Site Characterization, does not describe or provide a reference to the conceptual site models (CSM) used during the risk assessment or the remedial actions at the Harmon Annex. Conceptual Site Models are useful tools for understanding the occurrence and exposure pathways of the contaminants identified at environmental remediation sites. The CSM for IRP Site 39 is included in Appendix E of the Draft ROD yet the CSM is not discussed or referenced in Section 2.5. No CSM information is presented for IRP Site 18, if applicable, or IRP Site 19. Please revised the Draft ROD to present CSMs and provide a discussion of the CSMs that were used to described contamination for the IRP Sites at the Harmon Annex. This discussion will help frame a better understanding of the remedial actions that took place at the Harmon Annex IRP Sites.

Response to Specific Comment 10; The following Conceptual Site Model section will be inserted immediately after Section 2.5, as follows:

"Conceptual Site Models (CSMs) are useful in assessing the fate and transport of COPCs and evaluating potential exposure pathways relative to present and future receptors. In order to expedite the property transfer of Harmon Annex sites to GovGuam, the USAF established conservative cleanup standards based on the stringent USEPA Region IX Residential PRGs rather than conducting human and ecological risk assessments. A CSM that is applicable to Sites 18,19, and 39 is presented in Appendix E of the Final El for Harmon OU (EA, 2000)."

Decision Summary, Section 2.5.2. The fourth paragraph in Section 2.5.2, Site 19 Contaminant Characteristics, discusses dioxin sampling results. The fourth sentence in this paragraph states "As shown in Table 2-5, only dioxin results analyzed by Method 8290 were used due to a more sensitive detection limit." The meaning of this sentence is not clear - specifically it is not clear specifically what the Method 8290 results were "used" for, in this discussion of the remediation process. In addition, more information on the dismissal of the Method 8280 results would be appropriate in the ROD considering Method procedures, sample

Final Record of Decision 4-5 July 2002 Harmon Annex Operable Unit characteristics, laboratory quality control, and aspects of the data validation that support discounting the use of the Method 8280 results. Please revise Section 2.5.2 of the ROD to provide this additional information on the dioxin results for IRP Site 19.

Response to Specific Comment 11: The third sentence of the fourth paragraph of Section 2.5.3 will be revised to state that:

"As presented in Tables 2-4 and 2-5, at Parcel A, in the fill area on the southwest corner of the site, benzo(a) pyrene, manganese, and dioxins were detected at concentrations above Residential PRGs (Figure 2-14). The initial dioxin subsurface soil samples collected from Site 19 during the RI were analyzed using USEPA Method SW8280. As the Method SW8280 reporting limits (RLs) for individual congeners were above their respective Residential PRGs the data set did not meet DOOs. Subsequently, one subsurface soil sample was collected from each of two locations (AAFB04S19S022 andAAFB04S19S023) in Parcel A. These subsurface samples were analyzed for dioxins using Method SW8290. As presented in Table 2-5, Method SW8290provided significantly lower RLs than Method SW8280. Sample AAFB04S10S023, as analyzed by Method SW8290, also included dioxins at concentrations above Residential PRGs. However, in accordance with an agreement between the USAF, GEPA, and the USEPA Region IX, the subsurface dioxin cleanup standard was established at 1.0 microgram per kilogram (µg/kg) and no cleanup was recommended for dioxins at Parcel A (IT/OHM, 1999b)."

Page 2-8, Section 2.5.1. Please include more information from the Decision Summary, No Further Action Planned for IRP Site 18 (dated September, 1997), to justify this conclusion. Four soil samples in 42 acres does not sound like enough, unless you include the trenching, geophysical work and soil vapor testing that was also performed. Also explain that the four samples were biased in that they were taken from the only areas that had any potential sources of contamination.

Response to Specific Comment 12: The first and third paragraphs of Section 2.5.2 will be revised as follows:

"Site 18 is located in an undeveloped area of the Harmon Annex. Based on several record searches, site reconnaissance, geophysical survey, 21 test ditch excavations, and 14 active and 1 passive soil gas samples there was no supporting evidence that the site was ever used as a landfill (EA, 2000). No stressed vegetation, stained soil, or fill materials were identified at Site 18 that could be deemed as evidence of waste disposal activities."

"Four biased surface soil samples (including one duplicate sample) were collected at Site 18. All surface soil samples were collected from 2.0 to 4.0 inches (0.2 to 0.3 feet) bgs and were analyzed for semivolatile organic compounds (SVOCs) and metals (inorganics)."

Page 2-9, Section 2.5.2. Please change the last sentence in the second paragraph to something like: "The drum was wrapped in plastic and was subsequently disposed of ______(insert off-island, into main base landfill, recycled, etc.).

Response to Specific Comment 13: The last sentence of the second paragraph of Section 2.5.3 will be revised to state that:

Final Record of Decision 4-6 July 2002 Harmon Annex Operable Unit "The drum was wrapped in plastic and was subsequently disposed of off-island."

Page 2-10, Second Paragraph. Same comment as above.

Response to Specific Comment 14: The second paragraph of Page 2-11 will be revised to state that:

"This drum was wrapped in plastic and was subsequently disposed of off-island."

Page 2-10, First Paragraph. The statement "the potential for exposure is unlikely" is not sufficient to explain why a hot spot of COCs found at a depth of 10 feet do not pose a risk. Either provide a conclusion from a risk assessment that the site wide risk is acceptable, or you may have to have an institutional control with a restriction against digging to that depth.

Response to Specific Comment 15; The fifth paragraph of Section 2.5.3 revised to read:

"As presented in Tables 2-4 and 2-5, three subsurface soil samples and a duplicate soil sample were collected from between 10 and 14 ft bgs, in the southwest corner Jill area of Parcel A (Figure 2-14). Benzo(a) pyrene (SVOCs by USEPA MethodSW8270) was detected in a single sample (AAFB04S19S030 at 140 µg/kg) at a concentration that exceeded the Residential PRG (56 µg/kg), but less than the Industrial PRG (360 µg/kg). This result was considered suspect as benzo(a) pyrene was not detected in the same sample using the more accurate USEPA Method SW8310, and benzo(a) pyrene was not detected in the duplicate sample (AAFB04S19S031D) using either Method SW8270 or SW8310. Manganese was detected in a single sample (AAFB04S19S023 at 7,090 mg/kg) at a concentration that exceeded the Residential PRG (3,120 mg/kg). However, this manganese concentration is just below the revised BTV of 7,100 mg/kg (EA, 2001). Total dioxin (Toxicity Equivalent Quotient [TEQ] by USEPA Method SW8290) was detected in subsurface soil sample AAFB04S19S023 (0.0164 µg/kg) at concentrations exceeding the Residential PRG (0.0038 µg/kg), but less than the industrial PRG (0.03 µg/kg). This TEQ concentration is considerably lower than the subsurface dioxin cleanup standard of 1.0 µg/kg established by the USAF, GEPA, and the OSWER directive (IT/OHM, 1999c), and no further action is required.

Page 2-10, Third Paragraph. What does impacted by dioxins mean. Is this above or below action levels. If this is above action levels, then the statement "at depths unlikely for potential exposure" is again not sufficient. If so, then either provide a conclusion from a risk assessment that the site wide risk is acceptable, provide an institutional control with a restriction against digging to that depth, or do the following. Move and edit the second paragraph down from this one up and explain that the agreement between EPA and the Air Force about dioxin concerns an EPA OSWER Directive (1998, number 9200.4-26) that says that dioxin cleanup levels should be 1 ppb in soil. The Air Force decided to be more conservative than the EPA cleanup level for near surface soils.

Response to Specific Comment 16; The third sentence of the third paragraph of Page 2-11 will be revised to state that:

Final Record of Decision 4-7 July 2002 Harmon Annex Operable Unit "The subsurface fill area on the northern portion of Parcel B also included samples with dioxins at concentrations above the Residential PRG. As mentioned earlier, USEPA Method SW8280 was used for dioxin analysis during the initial subsurface soil sampling at Site 19. To compare the dioxin sample results of Method SW8280 and Method SW8290, one subsurface soil sample each was collected from the same locations in Parcel B as samples AAFB04S19S019 andAAFB04S19S032. These subsurface samples were analyzed for dioxins using Method SW8290. When comparing dioxin sample results of Method SW8280 and Method SW8290, Method SW8290 provided significantly lower RLs, below the respective Residential PRGs (Table 2-5). Subsequently, the USAF, GEPA, and the USEPA Region IX established the subsurface dioxin cleanup standard at 1.0 µg/kg and no cleanup for dioxins was necessary at Parcel B (IT/OHM, 1999c)."

Page 2-11, First Paragraph. Again, a statement like "Risks to groundwater ... are unlikely" is not sufficient. Its probably best to just delete this sentence.

Response to Specific Comment 17; The last two sentences of Section 2.5.3 will be revised to state that:

"As presented in Table 2-6, no VOCs, SVOCs, PAHs, pesticides/PCBs, or metals have been detected consistently in any of the samples collected from IRP-38 at concentrations above the MCLs or PRGs for tap water, with the exception of chromium. However, chromium is attributed to corrosion of the stainless steel piston pump and well screen and it is not believed to represent groundwater contamination."

Decision Summary, Section 2.5.2. The second-to-last paragraph in Section 2.5.2 (page 2-10), Site 19 Contaminant Characteristics, references an agreement between the USAF and USEPA Region IX related to the dioxin cleanup standard applied at the Harmon Annex. The sentence describing this agreement provides a reference to "USEPA, 1998." The only reference provided in Section 4, References, of the Draft ROD for USEPA, 1998 is a reference to the U.S. EPA Region IX Preliminary Remediation Goals. It seems that a references should be provided for OSWER Directive 9200.4-26, the April 13, 1998 directive from Tim Fields related to dioxin cleanup levels. Please revise Section 2.5.2 of the ROD to address this discrepancy.

Response to Specific Comment 18: The reference to "(USEPA, 1998)" will be corrected to cite:

"(IT/OHM, 1999b)"

Section 2.6. This entire section is confusing. The second paragraph on page 2-13 says that a risk assessment was performed for any residual COCs left behind, then a general overview of the RA process is provided in Section 2.6.1. However, Sections 2.6.3 and 2.6.4 say that no risk assessment was necessary. It might be better to end Section 2.6 with a statement that the sites were cleaned to meet either PRGs or to levels determined to be protective in a Risk Assessment. Then move directly to the individual site discussions beginning with Section 2.6.3.

Final Record of Decision 4-8 July 2002 Harmon Annex Operable Unit Response to Specific Comment 19: Sections 2.6.1 and 2.6.2 will be omitted and the last paragraph of Section 2.6 will be revised to state that:

"To expedite the transfer of Harmon Annex sites to GovGuam, the USAF established conservative cleanup standards based on the stringent USEPA Region IX Residential PRGs. An Action Memorandum was developed and soils above the residential PRGs were removed except for one location, the PAHs at the buried drum area of Site 39. Based on a human health risk assessment, the residual PAH concentrations at the buried drum area resulted in acceptable risks to human health."

Page 2-17. In the first paragraph of the page, delete the two sentences "Therefore, no human ... using the stringent Residential PRGs". Change the second paragraph to: The cleanup of hot spots at Parcels A and C was proposed to protect human health from exposure to COCs. The Air Force selected the most stringent cleanup standards, those for Residential PRGs. Because all COCs were removed to meet the Residential PRGs, no risk assessment was necessary. The cleanup standards for Site 19 were: (Then continue on with the bullets).

Response to Specific Comment 20: The third paragraph of Page 2-15 will be omitted and the second paragraph will be revised to state that:

"The cleanup of hot spots at Parcels A and C was proposed to protect human health from exposure to COCs. Andersen AFB selected the most stringent cleanup standards, those for Residential PRGs. Because all COCs were removed to meet the Residential PRGs, no risk assessment was necessary. The cleanup standards for Site 19 were:"

Page 2-17. In the last two paragraphs, should the references to Site 39 really be Site 19.

Response to Specific Comment 21; The fourth sentence of the fourth paragraph of Page 2-15 and the sixth sentence of the last paragraph of Page 2-16 will be respectively revised to state that:

"After the completion of remedial actions, Site 19 was restored by backfilling the excavation pits using compacted clean fill materials."

"Another drum, with approximately 25 gallons of liquid, was consolidated and transported to the U.S. mainland for disposal as hazardous materials (IT/OHM, 1999b)."

Page 2-18, first Paragraph. Change the language for the composite samples to include the number of samples in the composite, i.e., a composite of X samples ...

Response to Specific Comment 22: The second and third sentences of the first complete paragraph of Page 2-16 will be revised to state that:

"One six-point composite confirmation sample was collected at 6 feet bgs. One four-point composite sample was also collected from the stockpiled soil."

Final Record of Decision 4-9 July 2002 Harmon Annex Operable Unit Page 2-18, fourth Paragraph. Change the paragraph to read: "Based on analytical results from the 17 confirmation samples collected from the stockpiled soil, approximately 970 CY had acceptable lead and antimony concentrations. However, 530 CY of soil had lead concentrations exceeding the cleanup standard. The 530 CY ...".

Response to Specific Comment 23: The first and second sentences of the fourth complete paragraph of Page 2-16 will be revised to state that:

"Based on analytical results from 17 confirmation samples collected from the stockpiled soil, approximately 970 CY had acceptable lead and antimony concentrations. However, 530 CY of soil had lead concentrations exceeding the cleanup standards (Appendix B)."

Page 2-23, Section 2.7. Edit the first sentence to "... have been removed from these sites and the sites are already ...".

Response to Specific Comment 24; Section 2.7 will be revised to state that:

"The No Further Action alternative was selected for the Harmon Annex OU because all COCs have been removed from these sites and the sites are already in a protective state posing no current or future risks to human health and the environment."

Decision Summary, Section 2.7.3. The text in Section 2.7.3, No Further Action Alternative for Site 39, mentions residual dioxin remaining at the site and references the Risk Assessment that was conducted to assess residual risk related to this compound at this site. Following excavation activities described in Section 2.6.5, it seems that residual benzo(a) pyrene concentrations remain at IRP Site 39 in addition to dioxin. Section 2.7.3 does not mention that residual concentrations of this compound remain at IRP Site 39 nor does this section provide a reference to the risk assessment that supports leaving concentration of this compound in place at the site at levels exceeding the EPA Region IX PRGs. Please revise Section 2.7.3 of the ROD to address residual benzo(a) pyrene remaining at IRP Site 39.

Response to Specific Comment 25; The first sentence of the second paragraph of Section 2.7.3 will be revised to state that:

"Residual dioxin and benzo(a) pyrene risks remaining at the site are acceptable to human health and the environment in accordance with risk assessment results presented in Appendix C."

Page 2-24, Section 2.8. Change the phrase 'significant comments' to 'substantive comments'.

Response to Specific Comment 26: The second sentence of Section 2.8 will be revised to state that:

"Upon closure of the comment period, no substantive comments were received from either the public or the Territory of Guam."

Decision Summary, Table 2-16. Table 2-16 summarizes Applicable or Relevant and Appropriate Requirements (ARAR) for IRP Sites 19 and 39. This Table does not identify some of the

Final Record of Decision 4-10 July 2002 Harmon Annex Operable Unit following which appear to be ARARs for the site: Federal Safe Drinking Water Act Maximum Contaminant Levels (MCL); RCRA regulations on land disposal restrictions (LDRs) and on landfills; Toxic Substances Control Act (TSCA) requirements governing the management of asbestos containing materials such as the transite pipe removed from Parcel C at IRP Site 19 and PCB materials from the oil-water separator; GovGuam's listing the Micronesian Starling as endangered, as described in Section 2.6 of the Screening Ecological Risk Assessment contained in the RI Report for Harmon Annex; and ARARs that may have been considered related to the historic or archeological aspects of the IRP Sites. Please revise Table 2-16 to included these ARARs, to the extent they are applicable to the work described in the ROD. Also, RCRA is listed as a territorial ARAR. It should be listed as a Federal ARAR.

Response to Specific Comment 27; Table 2-16 will be revised to expand the ARARs, as shown attached.

ERRATA

1. Declaration, Section 1.2. The second line in the second paragraph in this section references a document as "(1989a)." Please revise this reference to indicate USEPA as the author of this referenced document.

Response to Errata 1: The "(1989a)" will be replaced by "(USEPA, 1989a).

2. Decision Summary, Section 2.5.3. In the fifth paragraph, sixth line, of Section 2.5.3, Site 39 Contaminant Characteristics, please delete the word "was" between the two sentences.

Response to Errata 2: The sixth line of Section 2.5.4 will be revised as requested.

3. Decision Summary, Section 2.7.3. The second paragraph of Section 2.7.3, Description of No Further Action Alternative, references Appendix B for the risk assessment. The risk assessment is presented in Appendix E. Please revise the Draft ROD to address this discrepancy.

Response to Errata 3: The first sentence of the second paragraph of Section 2.7.3 will be revised to state that:

"Residual dioxin and benzo(a) pyrene risks remaining at the site are acceptable to human health and the environment in accordance with risk assessment results presented in Appendix C."

4. Decision Summary, Various Tables. Tables 2-3, 2-4, 2-7, 2-8, and 2-9 contain incomplete screening references in the column headers. The "Screening Basis" columns reference "1998 USEPA IX Residential" and "1998 USEPA IX Industrial." These column headers apparently should reference " 1998 USEPA Region IX PRGs" for Residential and Industrial scenarios. A similar discrepancy may be seen in Table 2-11. Please revise the tables in the ROD to provide clear information in the column headers.

Response to Errata 4: The heading for Tables 2-3, 2-4, 2-7, 2-8, 2-9, and 2-11 will be corrected. Final Record of Decision 4-11 July 2002 Harmon Annex Operable Unit 5. REFERENCES

Andersen Air Force Base (AFB), 2000. Final Management Action Plan, Andersen Air Force Base, Guam. December.

Division of Aquatic and Wildlife Resources (DAWR), 1994. Brochure of the Yellow Bittern. Funded by the Federal Aid in Sport Fish and Wildlife Restoration Programs. Hagatna, Guam.

EA Engineering, Science, and Technology (EA), 1997. Phase II Environmental Baseline Survey for P.L.103-339 Parcels: Harmon Annexes, Camp Edusa, Andersen Radio Beacon Annex, Harmon POL Storage Annex No. 1, Andersen South Administrative Annex for Andersen Air Force Base, Guam. April.

EA Engineering, Science, and Technology (EA), 1998a. Final Community Relations Plan for the Installation Restoration Program, Andersen Air Force Base, Guam. December.

EA Engineering, Science, and Technology (EA), 1998b. Draft Site Characterization Summary Report for Site 19/Landfill 24, Harmon Annex, Andersen Air Force Base, Guam. January.

EA Engineering, Science, and Technology (EA), 1998c. Site Characterization Summary Report for IRP Site 39/Harmon Substation, Andersen Air Force Base, Guam. January.

EA Engineering, Science, and Technology (EA), 1998d. Final Decision Document No Further Response Action Planned (NFRAP) for Site 18/Landfill 23, Harmon Annex, Andersen Air Force Base, Guam. February.

EA Engineering, Science, and Technology (EA), 2000. Final Remedial Investigation for Harmon Annex Operable Unit, Andersen Air Force Base, Guam. November.

EA Engineering, Science, and Technology (EA), 2001. Technical Memorandum on the Recalculation of Background Threshold Value (BTV) for Manganese in Soil, Installation Restoration Program (IRP) Sites, Andersen Air Force Base, Guam. December.

Guam Department of Commerce, 1999. Guam Annual Economic Review 1997-1998, Table p2.

Guam Environmental Protection Agency (GEPA), 1997. The Wellhead Protection Program, Water Resource Management Program, Harmon, Guam. pp. 3

Guam Waterworks Authority (GWA) 1999. Personal communication with F. Jaleco.

ICF Technology, Inc., 1993. Community Relations Plan for the Installation Restoration Program, Andersen Air Force Base, Guam. November.

ICF Technology, Inc., 1995. Phase I Environmental Baseline Survey Report For Andersen Air Force Base. Volume 1: Harmon Annex; Volume 2: Camp Edusa; Volume 3: Andersen Radio Beacon Annex; Volume 4: Harmon POL Tank Farm; Marbo Annex, Part I; Andersen Air Force Base, Guam. Final. January.

Final Record of Decision R-1 July 2002 Harmon Annex Operable Unit ICF Technology, Inc., 1996a. Operable Unit 3 Remedial Investigation Report. Review Draft. June.

ICF Technology, Inc. (ICF Technology), 1996b. Records Search for Andersen Air Force Base, Guam. Final. February.

IT/OHM Remediation Services Corp., 1999a. Remediation Activities at Areas of Concern 1, 2, 3,4, 5, 12, and 22. Public Law Parcels 103-339, Harmon Annexes, Andersen Air Force Base, Guam. September.

IT/OHM Remediation Services Corp., 1999b. Remediation Verification Report for IRP Site 19/Landfill 24, Andersen Air Force Base, Guam. June.

IT/OHM Remediation Services Corp., 1999c. Remediation Verification Report for Harmon Substation, Andersen Air Force, Guam. June.

Mink, J. F., 1976. Groundwater Resources of Guam: Occurrence and Development. WRRC Technical Report 1, Water Resources Research Center, University of Guam, September, 285 pp.

Public Utility Agency of Guam. 1992. Water Facilities Master Plan Update, Barrett Consulting Group, Honolulu, Hawaii. 275 pp.

United States Air Force (USAF), 1995. Environmental Restoration Program, NFRAP Guide, A resource for making, Documenting, and evaluation No Further Response Action Planned Decisions. United States Air Force, June.

United States Environmental Protection Agency (USEPA) Region IX, 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA. Interim Final. EPA/540/G-89/004. Office of Emergency and Remedial Response, Washington, D.C.

United States Environmental Protection Agency (USEPA), 1989a. Interim Final Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The Record of Decision, Explanation of Significant Differences, The Record of Decision Agreement. Report No. OSWER 9335.3-02. U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, Washington, D.C. October 1989.

United States Environmental Protection Agency (USEPA) Region IX, 1996. Drinking Water Regulations and Health Advisories, Report No. EPA/822-B-96-002, U.S. Environmental Protection Agency, Office of Water,, Washington, D.C. August.

United States Environmental Protection Agency (USEPA) Region IX, 1998. EPA Region IX Preliminary Remediation Goals Table (Update). U.S. Environmental Protection Agency, Region DC, San Francisco. June.

Ward, P. E., Hoffman, S. H., and Davis, D. A., 1965. Hydrology of Guam: U.S. Geological Survey Professional Paper 403-H. 28 p.

Final Record of Decision R-2 July 2002 Harmon Annex Operable Unit Appendix A

Andersen Air Force Base Administrative Record Index Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001

DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

27-Nov-96 Administrative Record Index LABAT-ANDERSON 1 INCORPORATED

01-Jun-84 SOW, Phase I Records Search HQ AFSEC/DEVP 2

01-Aug-84 GEPA Letter to Base Regarding Landfill Closure Branch, James B 3 Plan for Sites 01, 02, 03, 29, and 35 Guam Environmental Protection Agency

01-Mar-85 Phase I, Record Search Report Environmental 4 Science and Engineering, Inc.

30-May-85 Base Letter to Governor of Guam Regarding Phase I Sachse, Billy E, Col 5 Record Search 43 CSG/CC

05-Jun-85 Newspaper Article, "Air Force Probes Waste The Pacific Daily 6 Disposal- Sites" News

17-Jun-85 Newspaper Article, "Dump Site Study to Sample The Pacific Daily 7 Water" News

13-Aug-85 GEPA Letter to Base Regarding Comments on Phase Branch, James B 8 I Record Search Guam Environmental Protection Agency

18-Oct-85 Base Letter to GEPA Regarding Phase II Sachse, Billy E, Col 9 Presurvey Conference 43 CSG/CC

19-Mar-86 Congressman Letter to Secretary of the Air Force Synar, Mike 10 Regarding Phase I Record Search Guam House of Representatives

08-Apr-86 GEPA Letter to Base Regarding Landfill Closure Branch, James B 11 Plan for Sites 01, 02, 03, 29, and 35 Guam Environmental Protection Agency

Sep-86 Phase II, Technical Operations Plan, Battelle 12 Confirmation/Quantification Survey

08-Oct-86 EPA Region IX Letter to US General Accounting Takata, Keith 13 Office Regarding DoD Management of IRP and EPA Region IX Phase I Record Search Comments

Dec-86 RCRA Facility Assessment Report, Solid Waste Science Applications 14 Management Units International Corp.

13-Mar-87 GEPA Letter to Base Regarding SOW, Stage 1 Crisostomo, Charles 15 Comments Guam Environmental Protection Agency

1of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001

DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

19-May-87 GEPA letter to Base Regarding Site 01 Monitoring Crisostomo, Charles 16 Wells Guam Environmental Protection Agency

19-Jun-87 GEPA Letter to OEHL Regarding Sites 01, 02, and 03 Crisostomo, Charles 17 Monitoring Wells Guam Environmental Protection Agency

29-Feb-88 GEPA Letter to Base Regarding Landfill Closure Crisostomo, Charles 18 Plan for Sites 01, 02, 03, 29, and 35 Guam Environmental Protection Agency

01-Jul-88 GEPA Letter to Guam Attorney General Regarding Solivio, Rolando B 19 Legal Action for Landfill 5 Guam Environmental Protection Agency

11-Aug-88 GEPA Letter to Base Regarding Comments on Draft Crisostomo, Charles 20 Final Report, Apr 88 Guam Environmental Protection Agency

17-Aug-88 GEPA Letter to Base Regarding Comments on Crisostomo, Charles 21 Landfill Closure Plan Modification Guam Environmental Protection Agency

30-Sep-88 GEPA Letter to Base Regarding Approval of Landfill Crisostomo, Charles 22 Closure Plan Modification Guam Environmental Protection Agency

30-Sep-88 GEPA Letter to Base Regarding Comments on Crisostomo, Charles 23 Landfill Closure Plan Modification Guam Environmental Protection Agency

01-Nov-88 Revised Landfill and Waste Pile Closure Plan Battelle 24

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 25 Report, Volume I of VI

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 26 Report, Volume I of VI, Appendices A-G

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 27 Report, Volume II of VI, Appendix H-J

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 28 Report, Volume III of VI, Appendices K1-K2a

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 29 Report, Volume IV of VI, Appendix K2b

2of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001

DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 30 Report, Volume IV of VI, Appendix K2c

01-Jan-89 Phase II Stage 1, Final Confirmation/Quantification Battelle 31 Report, Volume VI of VI, Appendices L-N

01-Jan-89 Phase II Stage 2, Quality Assurance Project Plan Battelle 32

01-Jan-89 Phase II Stage 2, Work Plan Battelle 33

09-Jan-89 GEPA Letter to Base Regarding Comments on Crisostomo, Charles 34 Phase II Stage 2 Health and Safety Plan Guam Environmental Protection Agency

09-Feb-89 GEPA Letter to Base Regarding Landfill Post Closure Castro, Fred M 35 Permit Guam Environmental Protection Agency

21-Feb-89 GEPA Letter to Base Regarding Comments on Landfill Castro, Fred M 36 Modified Closure/Post Closure Plan Guam Environmental Protection Agency

24-Feb-89 GEPA Letter to Base Regarding Comments on Landfill Castro, Fred M 37 Post Closure Permit Guam Environmental Protection Agency

24-Feb-89 Newspaper Article, "Notice to Public" The Pacific Daily News 38

27-Mar-89 Base Letter to GEPA Regarding Modified Landfill Green, Frederick L, Col 39 Closure Plan 43 CSG/CC

03-Apr-89 GEPA Letter to Base Regarding Approval for Castro, Fred M 40 Amended Modified Landfill Closure Plan Guam Environmental Protection Agency

03-May-89 Base Letter to GEPA Regarding Exchange of Green, Frederick L, Col 41 Information and Comments on Landfill Closure Plan 43 CSG/CC

22-May-89 GEPA Letter to Base Regarding Comments in Base Castro, Fred M 42 Letter of 3 May 89 Guam Environmental Protection Agency

25-May-89 GEPA Letter to Base Regarding Groundwater Castro, Fred M 43 Monitoring Comments in Base Letter of 3 May 89 Guam Environmental Protection Agency

01-Jul-89 RCRA Post-Closure Permit Application, Sites 01, 02, Harding Lawson Associates 44 03, 29, and 35

10-Aug-89 Base Letter to GEPA Regarding RCRA Post-Closure Green, Frederick L, Col 45 Permit Application 43 CSG/CC 3of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

20-Sep-89 GEPA Letter to Base Regarding Landfill Cover, Castro, Fred M 46 Fence, and Test Results Guam Environmental Protection Agency

31-Oct-89 Base Letter to GEPA Regarding Landfill Closure Green, Frederick L, Col 47 Cover and Test Results 633 ABW/CC

06-Nov-89 GEPA Letter to Base Regarding Comments for FTA Solivio, Rolando B 48 and RCRA Landfill Closure Permit Guam Environmental Protection Agency

22-Nov-89 GEPA Letter to Base Regarding Landfill Closure Plan Solivio, Rolando B 49 Guam Environmental Protection Agency

01-Dec-89 Phase II Stage 2, Informal Technical Information Science Applications 50 Report, Vol I of III, Analytical Data International Corp.

01-Dec-89 Phase II Stage 2, Informal Technical Information Science Applications 51 Report, Vol II of III, Analytical Data International Corp.

01-Dec-89 Phase II Stage 2, Informal Technical Information Science Applications 52 Report, Vol III of III, Analytical Data International Corp.

02-May-90 GEPA Letter to Base Regarding Fire Training Area 2 Castro, Fred M 53 Guam Environmental Protection Agency

03-May-90 GEPA Letter to Base Regarding Comments on Castro, Fred M 54 Approved Landfill Closure Plan Guam Environmental Protection Agency

03-Aug-90 GEPA Letter to Base Regarding Fire Training Area 2 Castro, Fred M 55 Concrete Cap Guam Environmental Protection Agency

29-Aug-90 GEPA Letter to Base Regarding Landfill Closure Plan Castro, Fred M 56 Deficiencies Guam Environmental Protection Agency

13-Sep-90 Base Letter to GEPA Regarding Landfill Closure Plan DeGovanni, George, Col 57 Modification 633 ABW/CC

28-Sep-90 Base Letter to GEPA Regarding Landfill Closure Plan DeGovanni, George, Col 58 Modification 633 ABW/CC

03-Jan-91 GEPA Letter to Base Regarding Comments on Castro, Fred M 59 Modified Landfill Closure Plan Guam Environmental Protection Agency

04-Feb-91 EPA Region IX Letter to Base Regarding Comments EPA Region IX 60 on Comprehensive Groundwater Monitoring Evaluation 4of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

14-Mar-91 GEPA Letter to Base Regarding Comments on Fire Castro, Fred M 61 Training Area 2, "Decision for Remedial Action" Guam Environmental Protection Agency

22-Mar-91 Newspaper Article, "Air Force Continues Waste Sites The Pacific Daily News 62 Cleanup"

28-Mar-91 Modified Landfill Closure Plan Science Applications 63 International Corp.

15-Apr-91 News Release, "Public Hearing for Modified Closure 633 ABW/DEV 64 Plan on Base Landfill"

30-Apr-91 Base Letter to GEPA Regarding Negotiations for DeGovanni, George, Col 65 Modified Closure Plan for Base Landfill 633 ABW/CC

15-May-91 Public Hearing Meeting Minutes, 14 May 91 Mackey, Gary W 66 633 ABW/DEV

20-May-91 Base Letter to GEPA Regarding Requirements of Schauz, William G, LtCol 67 Public Notification for Modification of the Closure Plan 633 ABW/DE

24-May-91 Base Letter to EPA Region IX Regarding Cover Design Schauz, William G, LtCol 68 for Modified Landfill Closure Plan and Stage 3 SAP 633 ABW/DE

28-May-91 Base Letter to US Fish and Wildlife Service Regarding Nault, Gary S 69 Consultation on Endangered Species Act, Landfill 2 633 ABW/DEV

31-May-91 Base Letter to US Fish and Wildlife Service Regarding Nault, Gary S 70 Consultation on Endangered Species Act for 633 ABW/DEV Topographic Survey, Landfill 2

03-Jun-91 US Fish and Wildlife Service Letter to Base Regarding Smith, Robert P 71 Consultation for Clearing Vegetation, Landfill 2 US Fish and Wildlife Service

06-Jun-91 US Fish and Wildlife Service Letter to Base Regarding Smith, Robert P 72 Consultation on Endangered Species Act, Landfill 2 US Fish and Wildlife Service

08-Jul-91 GEPA Letter to Base Regarding Negotiated Modified Brown, Joanne M 73 Landfill Closure Plan Guam Environmental Protection Agency

16-Jul-91 Base Letter to US Fish and Wildlife Service Nault, Gary S 74 Regarding Consultation to Install 11 Boreholes 633 ABW/DEV

18-Jul-91 GEPA Letter to Base Regarding Approved Castro, Fred M 75 Modifications for Landfill Closure Plan Guam Environmental Protection Agency

5of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

26-Jul-91 EPA Region VII Letter to EPA Region IX Regarding Baxter, Terry E 76 Review Comments for Stage 3, SAP EPA Region VII

02-Aug-91 EPA Region IX Letter to AFCEE-ESO/ER Regarding Hagemann, Matthew 77 Comments for Exploratory Borehole Locations EPA Region IX

22-Aug-91 US Fish and Wildlife Service Letter to Base Kramer, William R 78 Regarding Consultation for Endangered US Fish and Wildlife Mariana Crow and Mariana Fruit Bat, Landfill 2 Service

28-Aug-91 Base Letter to GEPA Regarding Alternative Cover Schauz, William G, LtCol 79 Design for Landfill Cap 633 ABW/DE

03-Sep-91 Base Letter to GEPA Regarding Using a Synthetic Schauz, William G, LtCol 80 Cover for Landfill Cap 633 ABW/DE

04-Sep-91 Base Letter to GEPA Regarding Comments on DeGovanni, George, Col 81 Modifications on Closure Plan for Landfill Area 633 ABW/CC

13-Sep-91 Base Letter to GEPA Regarding Borehole Drilling Trowbridge, Julia A 82 633 ABW/DE

15-Sep-91 Documentation Report, Disposal Activities of Landfill ICF Technology, Inc. 83 1 and 2

16-Sep-91 Base Letter to GEPA Requesting Amendment to Trowbridge, Julia A 84 Modified Closure Plan 633 ABW/DE

24-Sep-91 GEPA Letter to Base Regarding Comments on Stage Brown, Joanne M 85 3 SAP Guam Environmental Protection Agency

24-Sep-91 GEPA Letter to Base Regarding for Exploratory Brown, Joanne M 86 Borehole Locations Guam Environmental Protection Agency

26-Sep-91 Base Letter to GEPA Regarding Failure to Receive Trowbridge, Julia A 87 Review Comments on Phase II Stage 2 RI/FS Report 633 ABW/DE

11-Oct-91 Newspaper Article, "Notice to the Public Regarding The Pacific Daily News 88 Availability of Amended Closure Item for Modified Closure Plan"

11-Oct-91 Base Letter to EPA Region IX Regarding Review Schauz, William G, LtCol 89 Comments on Proposal for Borehole Locations 633 ABW/DE

31-Oct-91 GEPA Letter to Base Regarding Site Inspection for Castro, Fred M 90 Borehole Activity Guam Environmental Protection Agency

6of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Nov-91 Groundwater Monitoring Plan Science Applications 91 International Corp.

01-Dec-91 Phase II Stage 2, Final RI/FS Technical Report, Science Applications 92 Vol I of VI International Corp.

01-Nov-91 Phase II Stage 2, Final RI/FS Technical Report, Science Applications 93 Vol II of VII, Appendices A and C-F International Corp

01-Nov-91 Phase II Stage 2, Final RI/FS Technical Report, Vol Science Applications 94 III of VII, Appendix G1 (Part 1) International Corp

01-Nov-91 Phase II Stage 2, Final RI/FS Technical Report, Science Applications 95 Vol IV of VII, Appendix G1 (Parts 2a-c) International Corp

01-Nov-91 Phase II Stage 2, Final RI/FS Technical Report, Science Applications 96 Vol V of VII, Appendix G1 (Part 3) International Corp

01-Nov-91 Phase II Stage 2, Final RI/FS Technical Report, Science Applications 97 Vol VI of VII, Appendix G2 (Parts la-b) International Corp

01-Nov-91 Phase II Stage 2, Final RI/FS Technical Report, Science Applications 98 Vol VII of VII, Appendix G2 (Parts 2a-b)- G5, International Corp H and K

05-Nov-91 GEPA Letter to Base Regarding Modification Request Castro, Fred M. 99 for "Conceptual Design Report, Landfill Operable Unit Guam Environmental Cap Design" Protection Agency

03-Dec-91 GEPA Letter to Base Regarding Comments for Brown, Joanne M 100 Synthetic Cap, "Conceptual Design Report, Landfill Guam Environmental Operable Unit Cap" Protection Agency

13-Dec-91 GEPA Letter to Base Regarding Comments on 16 Sep Brown, Joanne M 101 91 Letter Requesting Amendment for Modified Landfill Guam Environmental Closure Plan Protection Agency

13-Dec-91 SOW, RI/FS Stage 3, Part U AFCEE/ESR 102

23-Dec-91 Base Letter to GEPA Regarding Placing Topsoil Schauz, William G, LtCol 103 Cover on Site 27 633 ABW/DE

01-Jan-92 RI/FS Stage 3, Final Landfill Unit Work Plan ICF Kaiser Engineers 104

14-Jan-92 Base Letter to GEPA Regarding Alternative Cover Schauz, William G, LtCol 105 Designs for Landfill Cap, Site 02 633 ABW/DE

14-Jan-92 Base Letter to GEPA Regarding Transmittal of Draft Schauz, William G, LtCol 106 Design Drawings, Specifications, and Correspondence 633 ABW/DE for Alternative Cover Designs and Comments for Landfill Cap, Site 02 7of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

22-Jan-92 GEPA Letter to Base Regarding Comments on Field Castro, Fred M 107 Sampling Plan for Landfill 2 Test Pits and Background Guam Environmental Soil Samples Protection Agency

06-Feb-92 Newspaper Article, "Notice to Public Regarding The Pacific Daily News 108 Andersen AFB Proposed Placement on the NPL"

27-Feb-92 Base Letter to GEPA Regarding Boreholes Drilling Schauz, William G, LtCol 109 and Sampling Analysis 633 ABW/DE

01-Mar-92 Groundwater Dye Tracing Study, SAP ICF Kaiser Engineers 110

17-Mar-92 SOW, RI/FS Stage 3 and FTA Cover AFCEE/ERS 111

01-Apr-92 Geologic and Hydrogeologic Report of Landfill ICF Kaiser Engineers 112 Complex

07-Apr-92 US Fish and Wildlife Service Letter to Base Kramer, William R 113 Regarding Consultation for Surveying Sampling US Fish and Wildlife Service Site and Drilling Wells

22-Apr-92 GEPA Letter to Base Regarding Comments on Castro, Fred M 114 Groundwater Dye Tracer Study Guam Environmental Protection Agency

15-May-92 US Fish and Wildlife Service Letter to Base Regarding Smith, Robert P 115 Consultation to Define and Locate Landfill Boundaries, US Fish and Wildlife Service Fill Trenches, and Conduct Topographical Survey

19-Jun-92 US Fish and Wildlife Service Letter to Base Regarding Kramer, William R 116 Consultation Comments to Define and Locate Landfill US Fish and Wildlife Service Boundaries, Fill Trenches, and Conduct Topographical Survey

30-Jul-92 SOW, Landfill 5 Cap AFCEE/ESR 117

01-Aug-92 Fact Sheet, "Environmental Cleanup at Andersen 633CES/DEV 118 Air Force Base"

06-Oct-92 JACE Letter to EPA Region IX Regarding Andersen Swenson, Raymond T, LtCo 119 AFB CERCLA Federal Facility Agreement, Remaining Air Force Legal Services Issues Agency, Regional Counsel (JACE)

07-Oct-92 EPA Region IX Letter to HQ PACAF/DE Regarding Anderson, Julie 120 Andersen AFB CERCLA Federal Facility Agreement EPA Region IX

19-Oct-92 Guam Attorney General Letter to SAF/ESO Barrett-Anderson, 121 Regarding Federal Facility Agreement Elizabeth Guam Attorney General

8of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

18-Dec-92 SOW, RI/FS, OU-4 AFCEE/ESR 122

29-Jan-93 Federal Facility Agreement: EPA Region IX, GEPA, EPA Region IX 123 and USAF

01-Mar-93 EE/CA, OU-1, Landfill 5 ICF Technology, Inc. 124

01-Mar-93 RI/FS, Health and Safety Plan, OU-1 ICF Technology, Inc. 125

15-Mar-93 EPA Region IX Letter to Base Regarding Comments on Levine, Herbert 126 Draft Final Work Plans and SAPs for OU-2 and OU-3 EPA Region IX

15-Mar-93 EPA Region IX Letter to Base Regarding Comments on Levine, Herbert 127 EE/CA for Landfill 5 and CRP EPA Region IX

01-Apr-93 Landfill 5 Cap Construction, Site Safety and Health Hensel-Phelps 128 Plan Construction Co. Woodward-Clyde

01-Apr-93 Landfill 5 Cap Construction, Erosion Control Plan Hensel-Phelps 129 Construction Co. Woodward-Clyde

01-Apr-93 Landfill 5 Cap Construction, Sampling and Analysis Hensel-Phelps 130 Plan Construction Co. Woodward-Clyde

06-Apr-93 TRC Meeting Agenda, 06 Apr 93 633 CES/DEV 131

07-Apr-93 GEPA Letter to Base Regarding Comments on Castro, Fred M 132 EE/CA for Landfill 5 Guam Environmental Protection Agency

01-May-93 Landfill 5 Cap Construction, Construction Quality Plan Hensel-Phelps 133 Construction Co. Woodward-Clyde

15-May-93 Newspaper Article, "Public Notice for EE/CA, The Pacific Daily 134 Landfill 5"

22-Apr-93 GEPA Letter to Base Regarding Comments on CRP News Castro, Fred M 135 Guam Environmental Protection Agency

01-May-93 Fact Sheet, "Landfill 5 Removal Action at Andersen 633 CES/DEV 136 Air Force Base"

10-May-93 GEPA Letter to Base Regarding Comments on EE/CA, Castro, Fred M 137 Technical Specifications, Construction Quality Plan, Guam Environmental and Sampling and Analysis Plan for Landfill 5 Protection Agency

9of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

12-May-93 GEPA Letter to Hansel Phelps Construction Co. Castro, Fred M 138 Regarding Comments on Clearing and Grading of Guam Environmental Landfill 5 Protection Agency

12-May-93 TRC Meeting Minutes, 12 May 93 Stanfill, Ronnie A, Col 139 633 ABW/CV

28-May-93 Base Letter to GEPA Regarding Revised Landfill 5 Poland, Joan 140 Cap Construction Quality Plan (CQP) and Comments 633 CES/DEV on GEPA's CQP and SAP Comments

01-Jun-93 Technical Specifications, Landfill 5 Cap Design ICF Technology, Inc. 141

01-Jun-93 RI/FS, Expanded Source Investigation Work Plan, ICF Technology, Inc. 142 OU-6

21-Jun-93 US Fish and Wildlife Service Letter to Base Regarding Smith, Robert P. 143 Reinitiation of Endangered Species Act Section 7 US Fish and Wildlife Service Consultation 1-2-92-F-08, Landfills

28-Jun-93 GEPA Letter to Base Regarding Comments for Landfill Wuerch, Victor 144 5 Cap Construction Quality Plan, Technical Guam Environmental Specifications, and Sampling and Analysis Plan Protection Agency

15-Jul-93 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 145 for Expanded Source Investigation Work Plan EPA Region IX

19-Jul-93 GEPA Letter to Base Regarding Comments on Wuerch, Victor 146 Expanded Source Investigation Work Plan Guam Environmental Protection Agency

29-Jul-93 Informal Technical Information Report, Title II Jacobs Engineering Group Inc. 147 Services, Landfill 5 Cap

23-Aug-93 SOW, RI/FS, OU-6 AFCEE/ESR 148

26-Aug-93 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 149 for OU-6 Basewide Work Plan and SAP EPA Region IX

01-Sep-93 Basewide Health and Safety Plan, OU-6 ICF Technology, Inc. 150

07-Sep-93 GEPA Letter to Base Regarding Comments for RI/FS, Wuerch, Victor 151 Basewide Work Plan and SAP, OU-6 Guam Environmental Protection Agency

07-Oct-93 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 152 For RI/FS, Work Plan and SAP, OU-2 EPA Region IX

29-Oct-93 RPM Meeting Minutes, 8-10 Sept 93 Poland, Joan 153 633 CES/CEVR

10of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Nov-93 RI/FS, Health and Safety Plan, OU-1 ICF Technology, Inc. 154

01-Nov-93 RI/FS, Health and Safety Plan, OU-2 ICF Technology, Inc. 155

01-Nov-93 RI/FS, Health and Safety Plan, OU-3 ICF Technology, Inc. 156

01-Nov-93 RI/FS, Health and Safety Plan, OU-4 ICF Technology, Inc. 157

01-Nov-93 RI/FS, Health and Safety Plan, OU-5 ICF Technology, Inc. 158

01-Nov-93 Community Relations Plan ICF Technology, Inc. 159

04-Nov-93 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 160 for RI/FS, Work Plan and SAP, OU-3 EPA Region IX

01-Dec-93 Landfill 5 Cap Construction, Certification of Hensel-Phelps 161 Closure Report Construction Co. Woodward-Clyde

01-Dec-93 Landfill 5 Cap Construction, Operation and Hensel-Phelps 162 Maintenance Manual Construction Co. Woodward-Clyde

06-Dec-93 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 163 on RI/FS Work Plan and SAP, OU-1 EPA Region IX

16-Dec-93 GEPA Letter to Base Regarding Comments on RI/FS Wuerch, Victor 164 Basewide Work Plan and SAP, OU-6 Guam Environmental Protection Agency

01-Jan-94 Fact Sheet, "TRC Update" 633 CES/CEVR 165

01-Jan-94 Final Inspection Report, Landfill 5 Cap Jacobs Engineering Group Inc. 166

07-Jan-94 Base Letter to EPA Region IX Regarding Base 633 CES/CEVR 167 Comments on RI/FS Work Plan, OU-2

11-Jan-94 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 168 on RI/FS Work Plan and SAP, OU-4 EPA Region IX

13-Jan-94 EPA Region IX Letter to Base Regarding Levine, Herbert 169 Comments on RI/FS Basewide SAP, OU-6 EPA Region IX

21-Jan-94 GEPA Letter to Base Regarding Comments on RI/FS Wuerch, Victor 170 Work Plan and SAP, OU-1 Guam Environmental Protection Agency

01-Feb-94 RI/FS, Landfill 2 Cap Construction, Cost Evaluation ICF Technology, Inc. 171 Report

11of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Feb-94 Final Landfill 5 Cap Construction Report Hensel-Phelps 172 Construction Co. Woodward-Clyde

01-Feb-94 RI/FS, Natural Resource Survey Report, Vol I of II ICF Technology, Inc. 173

01-Feb-94 RI/FS, Natural Resource Survey Report, Vol II of II ICF Technology, Inc. 174

01-Feb-94 Fact Sheet, "Dye Tracer Project Near Completion" Guam Coastal 175 Management Program

08-Feb-94 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 176 on RI/FS Work Plan and SAP, OU-5 EPA Region IX

17-Feb-94 GEPA Letter to Base Regarding Comments on RI/FS Wuerch, Victor 177 Work Plan and SAP, OU-4 Guam Environmental Protection Agency

18-Feb-94 GEPA Letter to Base Regarding Comments on RI/FS Levine, Herbert 178 Work Plan, OU-3 Guam Environmental Protection Agency

21-Mar-94 GEPA Letter to Base Regarding Comments on RI/FS Wuerch, Victor 179 Work Plan and SAP, OU-5 Guam Environmental Protection Agency

07-Apr-94 TRC Meeting Minutes, 17 Feb 94 Stanfill, Ronnie A, Col 180 633 ABW/CV

14-Apr-94 SOW, RI/FS, OU-6 AFCEE/ERD 181

10-May-94 Base Letter to GEPA Regarding Landfill Complex Poland, Joan 182 Dye Trace Project Sampling 633 CES/CEVR

01-Jun-94 SOW, RI/FS, OU-3 AFCEE/ERD 183

23-Jun-94 EPA Region IX Letter to Base Regarding Comments Levine, Herbert 184 on RI/FS Work Plan and SAP, OU-4 EPA Region IX

01-Jul-94 Final Geologic and Hydrogeologic Report, Landfill ICF Technology, Inc. 185 Complex

25-Jul-94 GEPA Letter to Base Regarding Comments on RI/FS Wuerch, Victor 186 Work Plan and SAP, OU-4 Guam Environmental Protection Agency

02-Aug-94 SOW, RI/FS, OU-3 AFCEE/ERD 187

01-Sep-94 RI/FS, Final Sampling and Analysis Plan Addendum, ICF Technology, Inc. 188 OU-3

12of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Sep-94 RI/FS, Final Work Plan Addendum, OU-3 ICF Technology, Inc. 189

01-Sep-94 RI/FS/RD, Data Summary, Conclusions, and ICF Technology, Inc. 190 Recommendations for Initial RI Activities at Landfill 29, War Dog Borrow Pit, and Waste Pile 6

09-Sep-94 SOW, RI/FS, Mod 1 for OU-2 AFCEE/COR 191

01-Oct-94 RI/FS, Final Sampling and Analysis Plan Addendum, ICF Technology, Inc. 192 OU-2

01-Oct-94 RI/FS, Final Work Plan Addendum, OU-2 ICF Technology, Inc. 193

01-Oct-94 RI/FS, Informal Technical Information Report ICF Technology, Inc. 194 Ecological Habitat Survey of OU-3

01-Oct-94 RI/FS, Final Sampling and Analysis Plan Addendum, ICF Technology, Inc. 195 OU-4

01-Oct-94 RI/FS, Final Work Plan Addendum, OU-4 ICF Technology, Inc. 196

01-Oct-94 RI/FS, Final Sampling and Analysis Plan Addendum, ICF Technology, Inc. 197 OU-5

01-Oct-94 RI/FS, Final Work Plan Addendum, OU-5 ICF Technology, Inc. 198

19-Oct-94 SOW, RI/FS, OU-5 AFCEE/ESR 199

01-Nov-94 RI/FS, Final Sampling and Analysis Plan Addendum, ICF Technology, Inc. 200 OU-1

01-Nov-94 RI/FS, Final Work Plan Addendum, OU-1 ICF Technology, Inc. 201

11-Nov-94 SOW, RI/FS/RD, Test Pit and Test Trench AFCEE/ERS 202 Excavations

29-Nov-94 TRC Meeting Minutes, 07 Nov 94 Saunders, Ralph S, Jr, Col 203 633 ABW/CC

01-Jan-95 Fact Sheet, "Andersen Air Force Base's 633 CES/CEVR 204 Environmental Investigation"

01-Jan-95 RI/FS, Final Basewide Sampling and Analysis Plan, ICF Technology, Inc 205 OU-6

01-Jan-95 RI/FS, Final Basewide Work Plan, OU-6 ICF Technology, Inc 206

11-Jan-95 Meeting Minutes for Telephone Conference with Base, ICF Technology, Inc 207 GEPA, and EPA Region IX Regarding Monitoring Well Pumps, OU-2

13of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Feb-95 RI/FS/RD, Final Groundwater Dye Trace Program ICF Technology, Inc. 208 and Well Cluster Proposal for the Landfill Area

03-Feb-95 RI/FS/RD, Data Summary, Conclusions, and ICF Technology, Inc. 209 Recommendations for Initial RI Activities at Waste Pile 7, Waste Pile 5, and MARBO Laundry

15-Feb-95 RAB Meeting Minutes, 15 Feb 95 633 CES/CEVR 210

24-Feb-95 RPM Meeting Minutes, 15-16 Feb 95 633 CES/CEVR 211

09-Mar-95 EPA Region IX Letter to Base Regarding Comments Schutz, Michelle 212 on Draft Groundwater Monitoring Plan EPA Region IX

10-Mar-95 SOW, RI/FS, OU-1 AFCEE/ESR 213

20-Mar-95 RI/FS/RD, Data Summary, Conclusions, and ICF Technology, Inc. 214 Recommendations for Initial RI Activities at Relocated Waste Pile 6 and Relocated Landfill 29

24-Mar-95 RAB Meeting Minutes, 24 Mar 95 Saunders, Ralph S, Jr, Col 215 633 ABW/CC

24-Mar-95 SOW, RI/FS, OU-6 AFCEE/ESR 216

06-Apr-95 EPA Region IX Letter to Base Regarding Comments Schutz, Michelle 217 on RI/FS Base Background Soil Field Sampling Plan EPA Region IX

20-Apr-95 RAB Meeting Minutes, 20 Apr 95 Saunders, Ralph S, Jr, Col 218 633 ABW/CC

01-May-95 SOW, RI/FS, OU-1 AFCEE/ESR 219

08-May-95 Base Letter to GEPA Regarding Comments on Drilling Poland, Joan 220 Pilot Holes 633 CES/CEVR

18-May-95 RAB Meeting Minutes, 18 May 95 Saunders, Ralph S, Jr, Col 221 633 ABW/CC

19-May-95 RI/FS/RD, Soil Gas Results, Conclusions, and ICF Technology, Inc. 222 Recommendations Report, OU-3

22-May-95 RPM Meeting Minutes, 19-22 May 1995 633 CES/CEVR 223

24-May-95 Newspaper Article, "Putting the Lid on an Old Problem" 633 CES/CEVR 224

26-May-95 GEPA Letter to Base Regarding Comments on Wuerch, Victor 225 Monitoring Wells Report, MARBO Guam Environmental Protection Agency

01-Jun-95 RI/FS, Basewide Health and Safety Plan, OU-6 EA Engineering, 226 Science and Technology 14of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

06-Jun-95 EPA Region IX Letter to Base Regarding Comments Schutz, Michelle 227 on Draft Groundwater Monitoring Plan EPA Region IX

22-Jun-95 EPA Region IX Letter to Base Regarding Comments Schutz, Michelle 228 for Soil Gas Results, Conclusions, and EPA Region IX Recommendations for OU-3

29-Jun-95 SOW, EE/CA for FTA 2 and Landfill 9 in OU-4 AFCEE/ESR 229

20-Jul-95 SOW, RI/FS/RD, OU-3 AFCEE/ERD 230

21-Jul-95 Base Letter to EPA Region IX Regarding Responses 633 CES/CEVR 231 to EPA Comments on Soil Gas Results, Conclusions, and Recommendations Report for OU-3

24-Jul-95 GEPA Letter to Base Regarding Comments on Soil Wuerch, Victor 232 Gas Results, Conclusions, and Recommendations Guam Environmental Report for OU-3 Protection Agency

08-Aug-95 GEPA Letter to Base Regarding Comments on Draft Wuerch, Victor 233 Groundwater Monitoring Plan Guam Environmental Protection Agency

23-Aug-95 SOW, Third-Party Data Validation AFCEE/COR 234

18-Sep-95 Base Letter to EPA Region IX Requesting Modification Poland, Joan 235 to Testing Methods Specified in QAPP 633 CES/CEVR

01-Oct-95 RI/FS/RD, Final Groundwater Monitoring Plan ICF Technology, Inc. 236

01-Oct-95 RI/FS, Final Basewide Health and Safety Plan EA Engineering, 237 Science and Technology

11-Oct-95 EPA Region IX Letter to Base Regarding Comments Schutz, Michelle 238 on QAPP EPA Region IX

12-Oct-95 RAB Meeting Minutes, 12 Oct 95 Jaroch, Victor D, Col 239 36 ABW/CV

15-Nov-95 Base Letter to EPA Region IX Regarding Responses Poland, Joan 240 to Comments on Soil Gas Results, Conclusions, and 36 CES/CEVR Recommendations Report for OU-3

01-Dec-95 Final Management Action Plan EA Engineering, 241 Science and Technology

29-Jan-96 RI/FS, Data Summary, Conclusions, and ICF Technology, Inc. 242 Recommendations for Initial RI Activities at Waste Pile 3

15of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Feb-96 RI/FS, Final Records Search ICF Technology, Inc. 243

06-Feb-96 EPA Region IX Letter to Base Regarding Comments Schutz, Michelle 244 on Media Sample Data Report, OU-3 EPA Region IX

15-Feb-96 RAB Meeting Minutes, 15 Feb 96 Jaroch, Victor D, Col 245 36 ABW/CV

16-Feb-96 RPM Meeting Minutes, 15-16 Feb 96 36 ABW/CV 246

22-Mar-96 GEPA Letter to Base Regarding Responses to GEPA Wuerch, Victor 247 Comments on Soil Gas Results, Conclusions, and Guam Environmental Recommendations Report for OU-3 Protection Agency

01-Apr-96 RI/FS/RD, Groundwater Elevations and Water Level ICF Technology, Inc 248 Map, Informal Technical Information Report, MARBO Annex and Harmon Annex, Vol I of II

01-Apr-96 RI/FS/RD, Groundwater Elevations and Water Level ICF Technology, Inc 249 Map, Informal Technical Information Report, North And Northwest Fields, Vol II of II

26-Jun-96 RAB Meeting Minutes, 16 May 96 Jaroch, Victor D, Col 250 36 ABW/CV

26-Jun-96 SOW, EE/CA, Landfills 21, 23 and 26, Hazardous AFCEE/COR 251 Waste Storage Area 1, and Waste Pile 4, OU-4

04-Mar-96 SOW, EE/CA, Landfills 14, 15, and 16, and PCB AFCEE/COR 252 Storage Area

12-Jan-96 SOW, RI/FS, OU-2 AFCEE/ERD 253

01-Sep-93 EPA Superfund Technical Assistance Grants Fact Sheet HQ USEPA 254

19-Apr-01 Newspaper Article, "Andersen Landfill Waiting for The Pacific Daily News 255 Cleanup"

15-Oct-92 Newspaper Article, "EPA Puts Andersen on Superfund The Pacific Daily News 256 Priority List"

16-Oct-92 Newspaper Article, "Andersen is Named to Superfund" Tropic Topics 257

16-Oct-92 Newspaper Article, "Andersen Cleanup Contract The Pacific Daily 258 Awaits Agreement" News

01-Jul-94 Base Newsletter, Jul 94 633 CES/CEVR 259

20-Jul-95 EPA Region IX Letter to Base Regarding Review of Schutz, Michelle 260 Purge/Stablization Test for Groundwater Monitoring Wells EPA Region IX 16 of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

03-Aug-95 EPA Region IX Letter to Base Regarding Response to Schutz, Michelle 261 Comments of Purge Stablization Test EPA Region IX

14-Nov-95 Base Letter to EPA Region IX Regarding Proposed Poland, Joan 262 Landfill Groundwater Monitoring Well Network 36 CES/CEVR

08-Feb-96 GEPA Letter to Base Regarding Review of Draft Wuerch, Victor 263 Media Sample Data Report, OU-3 Guam Environmental Protection Agency

29-Aug-96 GEPA Letter to Base Regarding Review Comments Wuerch, Victor 264 on RI, OU-3 Guam Environmental Protection Agency

17-Sep-96 RAB Meeting Minutes, 15 Aug 96 Jaroch, Victor D, Co 265 36 ABW/CV

31-Oct-96 RPM Meeting Minutes, 24-25 Sep-96 36 CES/CEVR 266

06-Apr-93 Newspaper Article, "Chamoru Nation Seeks U.S. The Pacific Daily 267 Help in Local Cancer Study" News

10-Jul-92 Base Newspaper Article, " Community Relations Vital Poland, D. Joan 268 for Environmental Program" 633 CES

10-Nov-92 Newspaper Article, "Angel Santos Stakes Claim to Brooks, Donovan 269 Land" Pacific Daily News

14-May-93 News Release, "Public Notice, Schedule of Proposed Pacific Daily News 270 Deadlines for Completion of Draft Primary Documents: Work Plan, Sampling & Analysis Plan, RI Report, Feasibility Report, Proposed Plan, & ROD"

23-Mar-94 Letter from Atty Peter Sgro, Jr., to Base Regarding Sgro, Jr., Peter R. 271 Elevated Levels of Cadmium and Lead; Failure to Atty-At-Law Adhere to Quality Control & Quality Assurance of Drinking Water & Necessity for Public Hearings

19-Jul-94 GEPA Fax to Base Regarding Approval of the Damian, Francis 272 Reseeding of LF-5 GEPA

09-Aug-94 Fax Documents to Base Concerning Fact Sheet from Sgro, Jr., Peter R. 273 Atty Peter Sgro, Jr., on the EE/CA for LF-5 Atty-At-Law Community Relations Plan & Letter to PUAG & GEPA

01-Feb-95 Fact Sheet, "Andersen AFB Restoration Advisory 36 CES/CEVR 274 Board (RAB)"

21-Mar-95 Installation Restoration Program Site Tour 275

18-May-95 RAB Charter Revisions 36 CES/CEVR 276 17of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

26-Sep-95 RAB Letter Concerning Trichloroethylene Brown, Joanne M. 277 Contamination Senator, Guam Legislature

06-Jan-96 USEPA Region IX Letter to Base Regarding Schutz, Michelle 278 Comments on the Basewide QAPP USEPA Region IX

01-Apr-96 Newsletter Article, "Air Force Plans the Installation of 279 Air Stripper"

01-Aug-96 Newspaper Article, "Harmon Cliffline Permits Revoked" Sterne, Bernadette 280 Pacific Daily News

19-Aug-96 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 281 of the Draft OU-3 Feasibility Study Report 36 CES/CEVR

22-Aug-96 USEPA Region IX Letter to Base Regarding Comments Schutz, Michelle 282 on the OU-3 RI Report USEPA Region IX

23-Aug-96 GEPA Letter to Base Regarding Extension for Review Wuerch, H. Victor 283 of the OU-3 RI Report GEPA

30-Aug-96 Newsletter Article, "Defense Cleanup" Pasha Publication 284

18-Sep-96 Base Fax to USEPA Region IX Fax to Base Regarding Ikehara, Gregg N. 285 Second Attempt to Drill Hole in IRP 52a Well 36 CES/CEVR

04-Oct-96 USEPA Region IX Letter to GEPA Regarding Burnett, Bryant K. 286 Reported Drums Located on Marine Drive, Guam USEPA Region IX

11-Oct-96 Base Letter to Guam Governor Requesting AF Deloney, John M. Colonel, 287 Reconsidering Revocation of Harmon Cliffline Permit USAF 36 ABW/CC

15-Oct-96 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 288 of Draft NFRAP for IRP Site 7/LF-9 36 CES/CEVR

15-Oct-96 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 289 of Copies of Draft NFRAP for IRP Site 7/LF-9 36 CES/CEVR

16-Oct-96 News Article, "Landowners Threaten Forcible Eviction" Loerzel, Adrienne 290 Pacific Daily News

21-Oct-96 USEPA Region IX Letter to Base Regarding Schutz, Michelle 291 Comments on the OU-3 Focused Feasibility Study USEPA Region IX Report

22-Oct-96 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 292 OU-3 Focused Feasibility Study Report GEPA

23-Oct-96 Newspaper Article, "Well Contamination Needs Close (Editorial) 293 Scrutiny" Pacific Daily News

18of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

29-Oct-96 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 294 of the Consensus Statement and the Revised Primary 36 CES/CEVR Document Deadlines

29-Oct-96 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 295 of Copies of the Consensus Statement and the Revised 36 CES/CEVR Primary Document Deadlines

29-Oct-96 Water Issues Between the Air Force & Public Utilities Quintanilla, R. 296 Agency of Guam PUAG

01-Nov-96 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 297 of the Draft OU-2 RI Report & Appendices 36 CES/CEVR

15-Nov-96 Extended Draft Final RI Report for OU-3, MARBO & Wuerch, H. Victor 298 Updated Risk Assessment Concurrence Guam EPA

21-Nov-96 RAB Meeting Minutes, 21 Nov 96 EA Engineering 299

01-Dec-96 OU-3, Remedial Investigation Report Vol 1 - Text, ICF Technology 300 Final

01-Dec-96 OU-3, Remedial Investigation Report Vol 2 - ICF Technology 301 Appendices A through D, Final

01-Dec-96 OU-3, Remedial Investigation Report Vol 3 - ICF Technology 302 Appendix E, Final

01-Dec-96 OU-3, Remedial Investigation Report Vol 4 - ICF Technology 303 Appendices F-l through F-7, Final

01-Dec-96 OU-3, Remedial Investigation Report Vol 5 - ICF Technology 304 Appendices F-8 through J, Final

09-Dec-96 RPM Meeting Minutes, 21-22 Nov 96 EA Engineering 305

02-Dec-96 Revised Risk Assessment Procedures Schutz, Michelle 306 USEPA Region IX

02-Dec-96 EPA Region IX Comments on Draft Final NFRAP for Schutz, Michelle 307 IRP Site 7/LF-9 USEPA Region IX

05-Dec-96 Amend Deadlines on Federal Facilities Agreement Schutz, Michelle 308 USEPA Region IX

09-Dec-96 Newspaper Article, "Asphalt from Bellows Pit Honolulu Star Bulletin 309 Recycled for Isle Potholes"

17-Dec-96 GEPA Fax to Base Regarding Review & Approval of Wuerch, H. Victor 310 Draft Final NFRAP for IRP Site 7/LF-9 GEPA

19of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

18-Dec-96 USEPA Region IX Letter to Base Regarding Schutz, Michelle 311 Procedure for Completion & Deletion of National USEPA Region IX Priorities List Sites

19-Jun-05 Article, "Community Involvement in Guam Helps Save Bureau of Planning 312 More than $175,000" Man, Land & Sea

01-Jan-97 OU-3, Focused Feasibility Study Report, Final ICF Technology 313

01-Jan-97 Final NFRAP for IRP Site 7/LF-9 EA Engineering 314

01-Jan-97 Fact Sheet, "Technology: Air Stripping" 36 CES/CEVR 315

06-Jan-97 USEPA Region IX Letter to Base Requesting Ripperda, Mark 316 Extension to the Comment Period for OU-2, RI Report, USEPA Region IX MARBO Annex

08-Jan-97 USEPA Region IX Letter to Base & GEPA Regarding Schutz, Michelle 317 30 Day Extension to Review Draft Final OU-3 RI Report USEPA Region IX

09-Jan-97 USEPA Region IX Letter to Base Regarding Review Ripperda, Mark 318 of the Draft RI Report for OU-2 MARBO Annex USEPA Region IX

09-Jan-97 Base Letter to RAB Members Regarding Transmittal Jaroch, Victor D. Colonel, 319 of Quarterly RAB Meeting Minutes, 21 Nov 96 USAF 36 ABW/CV

23-Jan-97 Base Letter to RAB Members Regarding Next Jaroch, Victor D. Colonel, 320 Quarterly RAB Meeting USAF 36 ABW/CV

24-Jan-97 GEPA Letter to Base Regarding Comments on the Draft Wuerch, H. Victor 321 RI Report for OU-2 GEPA

27-Jan-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 322 of the Draft Final OU-3 (MARBO Annex) Feasibility 36 CES/CEVR Study Report

27-Jan-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 323 Transmittal of Copies of the Draft Final OU-3 36 CES/CEVR (MARBO Annex) Feasibility Study Report

29-Jan-97 USEPA Region IX Letter to Base Regarding Response Opalski, Dan 324 to Review & Amendment of QAPP for Federal Facility USEPA Region IX Cleanup Sites

29-Jan-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 325 of the Final Revised Standard Operating Procedures (SOPs) for the RI/FS Activities

31-Jan-97 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 326 Draft RI Report for OU-2 GEPA

20of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

31-Jan-97 GEPA Letter to Base Regarding Comments on Phase II Wuerch, H. Victor 327 EBS for P.L. 103-339 Parcels GEPA

31-Jan-97 USEPA Region IX Letter to Base Regarding Response Opalski, Dan 328 to the Potential Impacts of the Eureka Laboratory Fraud USEPA Region IX Case of Federal Facilities Cleanup

01-Feb-97 Fact Sheet, "Harmon Annex" 36 CES/CEVR 329

12-Feb-97 Peer Review Report of Draft Final Focused Feasibility Poland, D. Joan 330 Study for OU-3 36 CES/CEVR

13-Feb-97 Technical Document to Support NFRAP Declaration 36 CES/CEVR 331 IPR Site 7/LF-9

19-Feb-97 Base Letter to GEPA Regarding Requesting Approval Poland, D. Joan 332 to Use Triangle Laboratories & Data Chem Labs to 36 CES/CEVR Conduct Dioxin and Furan Analyses

19-Feb-97 Base Letter to USEPA Region IX Regarding Requesting Poland, D. Joan 333 Approval to Use Triangle Laboratories & Data Chem 36 CES/CEVR Labs to Conduct Dioxin and Furan Analyses

21-Feb-97 Base Letter to USEPA Region IX Regarding Deadline Poland, D. Joan 334 Extension Request for Draft Feasibility Report for OU-2 36 CES/CEVR

26-Feb-97 Base Letter to Guam EPA (GEPA) Regarding Poland, D. Joan 335 Transmittal of NFRAP Documents for IRP Site 7/LF-9 36 CES/CEVR

26-Feb-97 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 336 of Final NFRAP Documents for IRP Site 7/LF-9 36 CES/CEVR

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 1 - Text, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 2A - Appendix A-C, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 2B - Appendix A-C, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 3A - Appendix E -F, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 3B - Appendix G, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 4A - Appendix H-I, Final

21of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 4B - Appendix J-L, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 5 - Appendix M-O, Final

01-Mar-97 OU-2, MARBO Annex, Remedial Investigation Report ICF Technology Vol 6 - Appendix P-T, Final

03-Mar-97 RPM Meeting Minutes, 12-13 Feb 97 EA Engineering 337

04-Mar-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 338 Notification of Laboratories to be Utilized by EA 36 CES/CEVR Engineering

30-Mar-97 Action Memorandum - Request & Document 36 CES/CEVR 339 Approval of Proposed Action for Site 39/Harmon Substation

02-Apr-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 340 of the Draft Final RI Report for Groundwater (OU-2) 36 CES/CEVR

02-Apr-97 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 341 of the Draft Final RI Report for Groundwater (OU-2) 36 CES/CEVR

03-Apr-97 USEPA Region IX Letter to Base Regarding Evaluation Opalski, Dan 342 of Base Response to Quality Assurance Questionnaire USEPA Region IX

03-Apr-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 343 Transmittal of Copies of the Draft Final Basewide 36 CES/CEVR Sampling & Analysis Plan, QAPP

03-Apr-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 344 of the Draft Focused Feasibility Study Report for 36 CES/CEVR Groundwater (OU-2)

03-Apr-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 345 Transmittal of Copies of the Draft Focused 36 CES/CEVR Feasibility Study Report for Groundwater (OU-2)

03-Apr-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 346 Transmittal of Copies of the Final OU-3 Focused 36 CES/CEVR Feasibility Report Revision Pages

03-Apr-97 Base Letter to GEPA Regarding Transmittal of Poland, D. Joan 347 Copies of the Final OU- Focused Feasiblity Report 36 CES/CEVR Revision Pages

03-Apr-97 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 348 of Copies of the Final OU-3 RI Revision Pages 36 CES/CEVR

22of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

03-Apr-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 349 of the Final OU-3 RI Revision Pages 36 CES/CEVR

08-Apr-97 RAB Quarterly Meeting Minutes, 20 Feb 97 Higgle, Albert F. Colonel, 350 USAF 36 SPTG/CC

09-Apr-97 Base Letter to GEPA Regarding Transmittal of Poland, D. Joan 351 Copies of Draft Final Phase II EBS for 36 CES/CEVR P.L. 103-339 Parcels

29-Apr-97 USEPA Region IX Letter to Base Regarding Ripperda, Mark 352 Comments on the Draft Final OU-2 RI Report USEPA Region IX

07-May-97 GEPA Letter to Base Regarding Comments on Wuerch, H. Victor 353 the Draft Final Basewide Sampling & Analysis GEPA Plan, QAPP and the Draft Final RI Report for Groundwater OU-2, MARBO Annex

07-May-97 USEPA Region IX Letter to Base Regarding Ripperda, Mark 354 Comments on the Draft Final QAPP USEPA Region IX

15-May-97 Base Letter to Mr. Tony Artero Regarding Riggle, Albert F. Colonel, 355 Assessment of Disposed Materials on Lot #10080 USAF 36 SPTG/CC

19-May-97 List of Interviewees for the IRP Community 36 CES/CEVR 356 Relations Plan Revisions

20-May-97 USEPA Region IX Letter to Base Regarding Ripperda, Mark 357 Comments on the Focused Feasibility Study Report USEPA Region IX for MARBO Annex OU-2 USEPA Region IX

29-May-97 Base Letter to USEPA Region IX Regarding Clarification Poland, D. Joan 358 to the QAPP for Federal Facility Cleanup Sites 36 CES/CEVR Questionnaire

29-May-97 Base Letter to GEPA Regarding Requesting Poland, D. Joan 359 Modifications to the OU-4 Work Plan for IRP Site 36 CES/CEVR 27/Hazardous Waste Storage Area 1 & OU-5 Work Plan for IRP Site 34/PCB Storage Area

29-May-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 360 Requesting Modifications to the OU-4 Work Plan for 36 CES/CEVR IRP Site 27/Hazardous Waste Storage Area 1 & OU-5 Work Plan for IRP Site 34/PCB Storage Area

03-Jun-97 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 361 Focused Feasibility Study for MARBO Annex OU-2 GEPA

19-Jun-97 Base Letter to RAB Members Regarding Next Quarterly Riggle, Albert F. Colonel, 362 RAB Meeting & Minutes of 15 May 97 RAB Meeting USAF 36 SPTG/CC

23of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

30-Jun-97 USEPA Region IX Letter to Base Regarding Approval Ripperda, Mark 363 to Use Method SW 3540 A/8310 for PAH Analysis USEPA Region IX

08-Jul-97 Summary of Community Interviews 36 CES/CEVR 364

11-Jul-97 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 365 Draft Proposed Plan for MARBO Annex OU 36 CES/CEVR (Soils & Groundwater)

11-Jul-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 366 Transmittal of the Draft Proposed Plan for MARBO 36 CES/CEVR Annex OU (Soils & Groundwater)

11-Jul-97 Base Letter to Mr. Tony Artero Regarding Completion Riggle, Albert F. Colonel, 367 of Field Work on Lot 10080 by AF's Environmental USAF 36 SPTG/CC Assessment Contractor

30-Jul-97 Base Letter to RAB Members Regarding Introductory McGoldrick, Tim Colonel, 368 Relative Risk Assessment Workshop for 31 Jul 97 USAF 36 ABW/CV

30-Jul-97 Recommended Community Relations Activities for 36 CES/CEVR 369 FY98

01-Aug-97 Fact Sheet, "Vertical Landfill Expansion" 36 CES/CEVR 370

14-Aug-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 371 of the Draft Final MARBO Annex OU-2 36 CES/CEVR (Groundwater) Focused Feasibility Study Report

14-Aug-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 372 Transmittal of the Draft Final MARBO Annex OU-2 36 CES/CEVR (Groundwater) Focused Feasibility Study Report

25-Aug-97 GEPA Fax to Base Regarding Comments on the Draft Wuerch, H. Victor 373 Proposed Plan for MARBO Annex OU GEPA

29-Aug-97 Base Letter to USEPA Region IX Regarding Poland, Joan 374 Transmittal of Copies of the Draft Final Proposed Plan 36 CES/CEVR for MARBO Annex OU (Soils & Groundwater)

29-Aug-97 Base Letter to GEPA Regarding Transmittal of Poland, Joan 375 Copies of the Draft Final Proposed Plan for MARBO 36 CES/CEVR Annex OU (Soils & Groundwater)

01-Sep-97 Fact Sheet, "Landfill 7" 36 CES/CEVR 376

23-Sep-97 GEPA Letter to Base Regarding Air Force Response Wuerch, D. Victor 377 to GEPA Comments on the MARBO Annex OU GEPA Focused Feasibility Study Report

24of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Oct-97 Final MARBO Annex OU-2 Focused Feasibility Montgomery Watson 378 Study Report

01-Oct-97 Final Basewide Quality Assurance Project Plan 379

01-Oct-97 Final Proposed Plan, MARBO Annex OU 36 CES/CEVR 380

01-Oct-97 IRP Newsletter, "Restoration Advisory Board 36 CES/CEVR 381 Recommends Cleanup Priorities"

08-Oct-97 News Release, "Notice of Availability, MARBO Pacific Daily News 382 Annex OU Proposed Plan"

14-Oct-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 383 of the Draft Decision Summary NFRAP for IRP Site 36 CES/CEVR 18/LF-23 & Copies of the Final Proposed Plan for MARBO Annex OU & Inserts for MARBO Annex OU-2 Focused Feasibility Study Report

20-Oct-97 Base Letter to GPA Authorizing Installation of Power Poland, D. Joan 384 Connection for IRP Contractor OHM 36 CES/CEVR

22-Oct-97 RPM Minutes, 22 Oct 97 EA Engineering 385

28-Oct-97 USEPA Letter to HQ ACC Regarding Clarification of Luftig, Stephen D. 386 Requirements for Administrative Record Files USEPA

21-Nov-97 RAB Meeting Minutes, 16 Oct 97 EA Engineering 387

24-Nov-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 388 of the Draft Decision Summary NFRAP for ERP Site 36 CES/CEVR 3/WP-3 & Copies of the Draft Site Characterization Report for WP 1, 2, & 3

24-Nov-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 389 Transmittal of Copies of the Draft Decision Summary 36 CES/CEVR NFRAP for IRP Site 3/Waste Pile 3 & Copies of the Draft Site Characterization Report for WP 1, 2, & 3

01-Dec-97 Final Quality Program Plan, Interim Remedial Actions, 390 Main Base, MARBO, & Harmon OUs, Vol 1

01-Dec-97 Final Environmental Cleanup Plan, Interim Remedial 391 Actions, Main Base, MARBO, & Harmon OUs, Vol 2

04-Dec-97 USEPA Region IX Letter to Base Regarding Comments Ripperda, Mark 392 on the Draft Decision Summary NFRAP for IRP Site USEPA Region IX 18/LF-23

09-Dec-97 USEPA Region IX Letter to Base Regarding Comments Ripperda, Mark 393 on the Draft Decision Summary NFRAP for IRP Site USEPA Region IX 3/Waste Pile 3 25of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

09-Dec-97 USEPA Region IX Letter to Base Regarding Comments Ripperda, Mark 393 on the Draft Decision Summary NFRAP for IRP Site USEPA Region IX 3/Waste Pile 3

09-Dec-97 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 394 of Copies of the Proposed Remediation Activities Project 36 CES/CEVR Memorandum for Waste Piles 1 & 2

09-Dec-97 Base Letter to GEPA Regarding Transmittal of Copies of Poland, D. Joan 395 the Proposed Remediation Activities Project Memorandum 36 CES/CEVR for Waste Piles 1 & 2

10-Dec-97 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 396 of Copies of the Draft Bioventing & Vapor Extraction 36 CES/CEVR Pilot Study for FTA-2

10-Dec-97 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 397 of the Draft Bioventing & Vapor Extraction Pilot Study 36 CES/CEVR for FTA-2

15-Dec-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 398 Transmittal of the Draft ROD for Soils & Groundwater 36 CES/CEVR MARBO Annex OU

15-Dec-97 Base Letter to GEPA Regarding Transmittal of the Draft Poland, D. Joan 399 ROD for Soils & Groundwater MARBO Annex OU 36 CES/CEVR

15-Dec-97 Base Letter to USEPA Region IX Regarding Poland, D. Joan 400 Modification to QAPP to Incorporate Method SW 8290 36 CES/CEVR for Analysis of Dioxins & Furans

15-Dec-97 Base Letter to GEPA Regarding Modification to QAPP Poland, D. Joan 401 to Incorporate Method SW 8290 for Analysis of Dioxins 36 CES/CEVR & Furans

01-Jan-98 Final Bioventing & Vapor Extraction Pilot Study EA Engineering 402 Work Plan FTA-2

28-Jan-98 GEPA Fax to Base Regarding Comments on the Wuerch, H. Victor 403 Draft Bioventing & Vapor Extraction Pilot Study GEPA Work Plan for FTA-2

01-Feb-98 Base Letter to GEPA Requesting Adjustments to Hodges, William Colonel, 404 AF Permit USAF 36 ABW/CC

02-Feb-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 405 Transmittal of Copies of the Action Memorandum 36 CES/CEVR & Site Characterization Summary Report for IRP Site 39/Harmon Substation

26of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

02-Feb-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 406 Final Bioventing & Vapor Extraction Pilot Study 36 CES/CEVR Work Plan for FTA-2

11-Feb-98 USEPA Region IX Letter to Base Regarding Comments Ripperda, Mark 407 on the Draft Final MARBO Annex OU ROD USEPA Region IX

25-Feb-98 Base Letter to GEPA Regarding Transmittal of Copies Ikehara, Gregg N. 408 of the NFRAP for IRP Site 18/LF-23 36 CES/CEVR

26-Feb-98 Base Letter to GEPA Regarding Transmittal of Copies Ikehara, Gregg N. 409 of the Site Characterization Report for IRP Site 19/LF-24 36 CES/CEVR

26-Feb-98 Base Letter to GEPA Regarding Transmittal of Copies Ikehara, Gregg N. 410 of the Draft Basewide Groundwater Summary Report 36 CES/CEVR

01-Mar-98 Decision Summary, NFRAP, BRP Site 3/Waste Pile 3 ICF Technology 411

01-Mar-98 Site Characterization Report, Waste Piles 1, 2, & 3 ICF Technology 412 Vol 1 - Text

01-Mar-98 Site Characterization Report, Waste Piles 1, 2, & 3 ICF Technology 413 Vol 2 - Appendices (2 of 2)

01-Mar-98 Fact Sheet, "Asphalt Recycling Operations" 36 CES/CEVR 414

04-Mar-98 RPM Meeting Minutes, 18 Feb 98 EA Engineering 415

23-Mar-98 Base Letter to GEPA Regarding Modification of the Poland, D. Joan 416 Target Analyte List in the Basewide QAPP 36 CES/CEVR

23-Mar-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 417 Modification of the Target Analyte List in the 36 CES/CEVR Basewide QAPP

24-Mar-98 Technical Document to Support NFRAP Declaration 36 CES/CEVR 418 for IRP Site 3/Waste Pile 3

26-Mar-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 419 Approval for Addition of OHM Services Corp to the 36 CES/CEVR QAPP

26-Mar-98 Base Letter to GEPA Regarding Approval for Poland, D. Joan 420 Addition of OHM Services Corp to the QAPP 36 CES/CEVR

26-Mar-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 421 Transmittal of Copies of the Final Decision 36 CES/CEVR Summary NFRAP for IRP Site 3/Waste Pile 3

27of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

26-Mar-98 Base Letter to GEPA Regarding Transmittal of Poland, D. Joan 422 Copies of the Final Decision Summary NFRAP 36 CES/CEVR for IRP Site 3/Waste Pile 3

31-Mar-98 USEPA Region IX Letter to Base Regarding Ripperda, Mark 423 Modifications to the QAPP Target Analyte List USEPA Region IX

31-Mar-98 USEPA Region IX Letter to Base Regarding Ripperda, Mark 424 Modifications to the QAPP USEPA Region IX

01-Apr-98 Fact Sheet, "Andersen AFB Restoration Advisory 36 CES/CEVR 425 Board (RAB)"

15-Apr-98 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 426 Action Memorandum & Site Characterization GEPA Summary Report for IRP Site 39/Harmon Substation & Addition of OHM Services Corp., EMAX Inc., to the QAPP

16-Apr-98 RPM Meeting Minutes, 16 Apr 98 36 CES/CEVR 427

16-Apr-98 Technical Document to Support NFRAP Declaration 36 CES/CEVR 428 for DIP Site 18/LF-23

30-Apr-98 Town Hall Meeting Minutes Regarding Landfill 7 Miclat, Marriane 429 Located in Base Housing 36 CES/CEVR

01-May-98 Final MARBO Annex OU Record of Decision 36 CES/CEVR 430

01-May-98 Base Letter to GPA Authorizing Installation of Poland, D. Joan 431 Power Connection for IRP Contractor OHM 36 CES/CEVR

15-Jun-98 RAB Meeting Minutes, 16 Apr 98 EA Engineering 432

15-Jun-98 US Dept of Interior to Base Regarding Concurrence DiRosa, Roger 433 of Base Finding for IRP Site 8/LFs 10A, 10B, IOC, Refuge Manager & IRP Site 33/Drum Storage Area 2 GNWR

15-Jun-98 UOG Letter to Base Regarding Resignation of Dr. Jenson, John W. Ph. D., 434 John Jenson from RAB & Nomination of Mr. John UOG, WERI Institute Jocson to RAB

01-Jul-98 Final Site Characterization Summary Report for EA Engineering 435 IRP Site 39/Harmon Substation

10-Jul-98 Press Release, "AAFB Conducts RAB Meeting" 36 CES/CEVR 436 Pacific Daily News

21-Jul-98 RAB Meeting Minutes, 16 Jul 98 EA Engineering 437

28of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

01-Aug-98 Newsletter Article, "Air Force Recycling Effort Paves Bureau of Planning 438 Island Roads" Man, Land, & Sea

01-Aug-98 Final Groundwater Summary Report for AAFB EA Engineering 439

01-Aug-98 Site Summary Report for FTA-2 Jacobs Engineering 440

01-Aug-98 Operation & Maintenance Plan, FTA-2, Soil Vapor Jacobs Engineering 441 Extraction System, AAFB

25-Aug-98 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 442 of the Final Groundwater Summary Report for AAFB 36 CES/CEVR

04-Sep-98 Base Letter to USEPA Region IX Regarding Transmittal Poland, D. Joan 443 of Copies of Updated Draft Community Relations Plan 36 CES/CEVR

04-Sep-98 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 444 of Updated Draft Community Relations Plan 36 CES/CEVR

04-Sep-98 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 445 of Final MARBO Annex OU ROD 36 CES/CEVR

13-Oct-98 Base Letter to GEPA Regarding Transmittal of the Draft Poland, D. Joan 446 Decision Summary NFRAP for IRP Site 11/Lfs 36 CES/CEVR l5A & 15B

13-Oct-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 447 Transmittal of Copies of Draft Decision Summary 36 CES/CEVR NFRAP for IRP Site ll/LFs 15A & 15B

19-Oct-98 USEPA Region IX Letter to Base Regarding Ripperda, Mark 448 Comments on the Draft Community Relations Plan USEPA Region IX

01-Nov-98 Final Spring 1998 Groundwater Data Monitoring Report EA Engineering 449

05-Nov-98 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 450 of Draft Quality Program Plan (Vol 1) & Draft 36 CES/CEVR Environmental Cleanup Plan (Vol 2) for MARBO Annex OU

05-Nov-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 451 Transmittal of Copies of the Draft Quality Program 36 CES/CEVR Plan (Vol 1) & Draft Environmental Cleanup Plan (Vol 2) for MARBO Annex OU

11-Nov-98 News Release, "Notice of Availability, ROD for the 36 CES/CEVR 452 MARBO IRP Sites" Pacific Daily News

12-Nov-98 News Release, "Notice of Availability, ROD for the 36 CES/CEVR 453 MARBO IRP Sites" Pacific Daily News

29of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

13-Nov-98 News Release, "Notice of Availability, ROD for the 36 CES/CEVR 454 MARBO IRP Sites" Pacific Daily News

23-Nov-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 455 Draft EE/CA for IRP Site 34/PCB Storage Area 36 CES/CEVR

23-Nov-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 456 Transmittal of the Draft EE/CA for IRP Site 34/PCB 36 CES/CEVR Storage Area

23-Nov-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 457 Transmittal of the Draft NFRAP for IRP Site 36 CES/CEVR 27/Hazardous Waste Storage Area 1

01-Dec-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 458 Transmittal of the Draft EE/CA for IRP Site 10/LF-14 36 CES/CEVR

01-Dec-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 459 Draft EE/CA for IRP Site 10/LF-14 36 CES/CEVR

08-Dec-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 460 Transmittal of the Project Memorandum for the 36 CES/CEVR Proposed Remediation Activities for P.L. 103-339 AOCs

08-Dec-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 461 Project Memorandum for the Proposed Remediation 36 CES/CEVR Activities for P.L. 103-339 AOCs

10-Dec-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 462 Transmittal of the Draft EE/CA for IRP Site 36 CES/CEVR 31/Chemical Storage Area 4

10-Dec-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 463 Transmittal of the Draft EE/CA for IRP Site 16/LF-21 36 CES/CEVR

10-Dec-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 464 Draft EE/CA for IRP Site 16/LF-21 36 CES/CEVR

10-Dec-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 465 Draft EE/CA for IRP Site 31/Chemical Storage Area 4 36 CES/CEVR

16-Dec-98 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 466 of the Final Community Relations Plan 36 CES/CEVR

16-Dec-98 Base Letter to USEPA Region IX Regarding Poland, D. Joan 467 Transmittal of Copies of the Final Community 36 CES/CEVR Relations Plan

16-Dec-98 Base Letter to GEPA Regarding Transmittal of the Poland, D. Joan 468 Draft Decision Summary Report for IRP Site 32/Drum 36 CES/CEVR Storage Area 1

30of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

28-Dec-98 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 469 Draft EE/CA for IRP Site 31/Chemical Storage Area 4 GEPA

29-Dec-98 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 470 Draft EE/CA for IRP Site 34/PCB Storage Area GEPA

06-Jan-99 RAB Meeting Minutes, 15 Oct 98 EA Engineering 471

06-Jan-99 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 472 Draft NFRAP for IRP Site 27/Hazardous Waste GEPA Storage Area 1

06-Jan-99 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 473 of the Draft Decision Summary Report for IRP 36 CES/CEVR Site 33/Drum Storage Area 2

06-Jan-99 Base Letter to USEPA Region IX Regarding Poland, D. Joan 474 Transmittal of Copies of the Draft Decision Summary 36 CES/CEVR Report for IRP Site 33/Drum Storage Area 2

15-Jan-99 USEPA Region IX Letter to Base Regarding Comments Ripperda, Mark 475 on Draft NFRAP Decision Document for IRP Site USEPA Region IX 27/Hazardous Waste Storage Area 1

16-Jan-99 USEPA Letter to Base Regarding Comments on Agency Ripperda, Mark 476 Draft EE/CA for IRP Site 34/PCB Storage Area USEPA Region IX

01-Feb-99 Final Decision Document NFRAP for IRP Site 11/ EA Engineering 477 LFs- 15A & 15B

13-Feb-99 USEPA Region IX Letter to Base Regarding Ripperda, Mark 478 Comments on Draft EE/CA for IRP Site 16/LF-21 USEPA Region IX

13-Feb-99 USEPA Region IX Letter to Base Regarding Ripperda, Mark 479 Comments on Draft EE/CA for IRP Site 31/Chemical USEPA Region IX Storage Area 4

19-Feb-99 USEPA Region IX Letter to Base Regarding Ripperda, Mark 480 Comments on Draft EE/CA for IRP Site 10/LF-14 USEPA Region IX

19-Feb-99 USEPA Region IX Letter to Base Regarding Ripperda, Mark 481 Concurrence of Sample Purge Field Change Request USEPA Region IX

19-Feb-99 USEPA Region IX Letter to Base Regarding Ripperda, Mark 482 Comments on Draft Decision Summary Report for USEPA Region IX IRP Site 32/Drum Storage Area 1

19-Feb-99 GEPA Letter to Base Regarding Comments on the Wuerch, H. Victor 483 Draft Decision Summary Report for IRP Site GEPA 32/Drum Storage Area 1

31of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

19-Feb-99 Dept of Interior Letter to Base Regarding Review of Ritter, Michael 484 the Proposed Work Plan for IRP Sites 28 & 12 Guam NWR

19-Feb-99 GEPA Letter to Base Regarding Comments on the Draft Wuerch, H. Victor 485 EE/CA for IRP Site 16/LF-21 GEPA

01-Mar-99 Final Basewide Quality Assurance Project Plan, EA Engineering 486 Revision 2.0

08-Mar-99 Cover Letter & RAB Meeting Minutes, 21 Jan 99 EA Engineering 487

22-Mar-99 Base Letter to GWA Regarding Status of Tumon-Maui Gehri, Mark J. D. 488 & MW-2 Water Wells & Possible Exploratory Activity Colonel, USAF at Harmon Annex 36 ABW/CC

25-Mar-99 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 489 of the Draft NFRAP for IRP Site 11/LFs ISA & 15B 36 CES/CEVR

01-Apr-99 Final NFRAP Decision Document for IRP Site EA Engineering 490 27/Hazardous Waste Storage Area 1

01-Apr-99 Final EE/CA for IRP Site 34/PCB Storage Area EA Engineering 491

10-Apr-99 News Release, "Vacancy Announcement Andersen 36 CES/CEVR 492 AFB Restoration Advisory Board Members" Pacific Daily News

11-Apr-99 News Release, "Vacancy Announcement Andersen 36 CES/CEVR 493 AFB Restoration Advisory Board Members" Pacific Daily News

12-Apr-99 News Release, "Vacancy Announcement Andersen 36 CES/CEVR 494 AFB Restoration Advisory Board Members" Pacific Daily News

15-Apr-99 RAB Meeting Minutes, 15 April 99 EA Engineering 495

20-Apr-99 News Article, "Officials Disagree on Wells" SantoTomas, Jojo 496 Pacific Daily News

27-Apr-99 Base Letter to Guam National Wildlife Refuge Larcher, Shawn D. 497 Regarding Conducting Environmental Investigations Capt, USAF at IRP Site 36/Ritidian Dump Site 36 CES/CEV

01-May-99 Final EE/CA for IRP Site 10/LF-14 EA Engineering 498

01-May-99 Final EE/CA Report for IRP Site 16/LF-21 EA Engineering 499

19-May-99 RPM Meeting Minutes, 19 May 99 EA Engineering 500

01-Jun-99 Decision Summary Report for IRP Site 33/Drum EA Engineering 501 Storage Area 2

01-Jun-99 Final EE/CA for IRP Site 31/Chemical Storage EA Engineering 502 Area 4 32of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

04-Jun-99 Base Letter to USEPA Region IX Regarding Poland, D. Joan 503 Transmittal of Copies of the Final Draft, EE/CA for 36 CES/CEVR IRP Site 34/PCB Storage Area, Site 10/LF-14, Site 16/LF-21, & Site 31/Chemical Storage Area 4

04-Jun-99 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 504 of the Final Draft, EE/CA for IRP Site 34/PCB Storage 36 CES/CEVR Area, Site 10/LF-14, Site 16/LF-21, & Site 31/Chemical Storage Area 4

09-Jun-99 Base Letter to USEPA Region IX Regarding Poland, D. Joan 505 Transmittal of Copies of the NFRAP Decision 36 CES/CEVR Document for IRP Site 27/Hazardous Waste Storage Area

09-Jun-99 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 506 of the NFRAP Decision Document for IRP Site 36 CES/CEVR 27/Hazardous Waste Storage Area

12-Jun-99 News Article, "Notice of Availability for IRP Sites: 36 CES/CEVR 507 LF-14, PCB Storage Area, Chemical Storage Area 4, & Pacific Daily News LF-21"

13-Jun-01 LF-14, PCB Storage Area, Chemical Storage Area 4, & 36 CES/CEVR 508 LF-21" Pacific Daily News

14-Jun-99 News Article, "Notice of Availability for IRP Sites: 36 CES/CEVR 509 LF-14, PCB Storage Area, Chemical Storage Area 4, & Pacific Daily News LF-21"

15-Jun-99 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 510 of Memos Discussing the Discontinuation of 36 CES/CEVR Groundwater Monitoring at NWF and Harmon

15-Jun-99 Fax Letter to Base Authorizing Air Force Limited Artero, Tony 511 Right of Entry to IRP Site 36/Ritidian Dump Site to Landowners Representative Conduct Environmental Survey

01-Jul-99 Remediation Verification Report, HIP Site 19/LF-24 IT Corporation 512

01-Jul-99 Remediation Verification Report, HIP Site 39/Harmon IT Corporation 513 Substation, Vol 1

01-Jul-99 Remediation Verification Report, IRP Site 39/Harmou IT Corporation 514 Substation, Vol 2

06-Jul-99 Base Letter to USEPA Region IX Regarding Poland, D. Joan 515 Transmittal of Copies of the Draft EE/CA Reports for 36 CES/CEVR IRP Site 21/LF-26

06-Jul-99 Base Letter to GEPA Regarding Transmittal of Copies Poland, D. Joan 516 of the Draft EE/CA Reports for IRP Site 21/LF-26 36 CES/CEVR

33of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

21-Jul-99 Base Letter to USEPA Region IX Regarding Poland, D. Joan 517 Appointment of Mr. Gregg Ikehara as New AAFB 36 CES/CEVR Remedial Project Manager (RPM)

21-Jul-99 Base Letter to GEPA Regarding Appointment of Mr. Poland, D. Joan 518 Gregg Ikehara As New AAFB Remedial Project 36 CES/CEVR Manager

30-Jul-99 Base Letter to GEPA Regarding Notification of a New Ikehara, Gregg N. 519 Project Laboratory with Columbia Analytical Services 36 CES/CEVR

30-Jul-99 Base Letter to USEPA Region IX Regarding Notification Ikehara, Gregg N. 520 of a New Project Laboratory with Columbia Analytical 36 CES/CEVR Services

30-Jul-99 Base Letter to GEPA Regarding Transmittal of Copies Ikehara, Gregg N 521 of the Remediation Verification Reports for TKP Site 36 CES/CEVR 39/Harmon Substation, Site 19/LF-24, & AOCs 1,2,3,4, 5, 12, & 22 at Harmon Annex

30-Jul-99 Base Letter to USEPA Region IX Regarding Transmittal Ikehara, Gregg N 522 of Copies of the Remediation Verification Reports for IRP 36 CES/CEVR Site 39/Harmon Substation, Site 19 LF-24, & AOCs 1,2,3, 4,5,12, & 22 at Harmon Annex

02-Aug-99 Base Letter to GEPA Regarding Transmittal of Copies of Ikehara, Gregg N 523 the Final Decision Summary Report for IRP Site 32/Drum 36 CES/CEVR Storage Area 1 & the Basewide QAPP, Rev 2

03-Aug-99 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N 524 Copies of the Final Fall 1998 and Spring 1999 Groundwater 36 CES/CEVR Data Monitoring Reports

03-Aug-99 Base Letter to GEPA Regarding Transmittal of Copies of Ikehara, Gregg N 525 the Final Fall 1998 and Spring 1999 Groundwater Data 36 CES/CEVR Monitoring Reports

06-Aug-99 Base Letter to GEPA Regarding Transmittal of the Final Ikehara, Gregg N 526 NFRAP Decision Documents for IRP Site 27/Hazardous 36 CES/CEVR Waste Storage Area

06-Aug-99 Base Letter to USEPA Region IX Regarding Transmittal Ikehara, Gregg N. 527 of Copies of the Final NFRAP Decision Documents for 36 CES/CEVR IRP Site 27/Hazardous Waste Storage Area

06-Aug-99 Base Letter to USEPA Region IX Regarding Transmittal Ikehara, Gregg N. 528 of Copies of the Draft Project Work Plans for IRP Site 36 CES/CEVR 34/PCB Storage Area, IRP Site 10/LF-14, IRP Site 16/LF-21 & IRP Site 31/Chemical Storage Area 4

34of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

06-Aug-99 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 529 Draft Project Work Plans for IRP Site 34/PCB Storage Area, 36 CES/CEVR IRP Site 10/LF-14, IRP Site 16/LF-21 & IRP Site 31/Chemical Storage Area 4

06-Aug-99 USEPA Region IX Letter to Base Regarding Comments on Ripperda, Mark 530 the Draft Decision Summary NFRAP for IRP Site 21/LF-26 USEPA Region IX

19-Aug-99 Base Letter to GEPA Regarding Proposed Variance Request Ikehara, Gregg N. 531 for Columbia Analytical Services Laboratory 36 CES/CEVR

19-Aug-99 Base Letter to USEPA Region IX Regarding Proposed Ikehara, Gregg N. 532 Variance Request for Columbia Analytical Services 36 CES/CEVR Laboratory

19-Aug-99 USEPA Region IX Letter to Base Regarding Approval of the Ripperda, Mark 533 Proposed Variance Request USEPA Region IX

19-Aug-99 USEPA Region IX Letter to Base Regarding Approval of the Ripperda, Mark 534 Remedial Verification Report for IRP Site 39/Harmon USEPA Region IX Substation

19-Aug-99 USEPA Region IX Letter to Base Regarding Approval of the Ripperda, Mark 535 Remedial Verification Report for HIP Site 19 LF-24 USEPA Region IX

24-Aug-99 USEPA Region IX Letter to Base Regarding Comments on Ripperda, Mark 536 the Draft Project Work Plans for IRP Site 34/PCB Storage USEPA Region IX Area, IRP Site 10/LF-14 IRP Site 16/LF-21 & IRP Site 31/Chemical Storage Area 4

27-Aug-99 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 537 Draft EE/CA for IRP Site 2/LF-2 & IRP Site 5/LF-7 36 CES/CEVR

01-Sep-99 Final Decision Summary NFRAP for IRP Site 21/LF-26 EA Engineering 538

09-Sep-99 Technical Document to Support NFRAP Declaration for 36 CES/CEVR 539 IRP Site 21/LF-26

15-Sep-99 RPM Meeting Minutes, 9 Sep 99 EA Engineering 540

28-Sep-99 Base Letter to GEPA Regarding Transmittal of the Ikehara, Gregg N. 541 Basewide QAPP Revision 2 & Final Reports for IRP Site 36 CES/CEVR 27/Hazardous Storage Area 1, Site 32/Drum Storage Area 1, & Site 33/Drum Storage Area 2

6-Oct-99 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 542 Copies of the Draft RI Report for Harmon Annex OU 36 CES/CEVR

6-Oct-99 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 543 Draft RI Report for Harmon Annex OU 36 CES/CEVR

35of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

12-Oct-99 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 544 Copies of the Final Decision Summary for IRP Site 21/LF-26 36 CES/CEVR

12-Oct-99 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 545 Final Decision Summary for IRP Site 21/LF-26 36 CES/CEVR

12-Oct-99 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 546 Copies of the Draft EE/CA for IRP Site 26/FTA-2 36 CES/CEVR

12-Oct-99 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 547 Draft EE/CA for IRP Site 26/FTA-2 36 CES/CEVR

13-Oct-99 GEPA Letter to Base Regarding Comments on Draft EE/CA Wuerch, H. Victor 548 Report for IRP Site 2/LF-2 GEPA

16-Oct-99 USEPA Region IX Letter to Base Regarding Comments on Ripperda, Mark 549 Draft EE/CA for IRP Site 5/LF-7 & IRP Site 2/LF-2 USEPA Region IX

22-Oct-99 GEPA Letter to Base Regarding Comments on Draft Decision Wuerch, H. Victor 550 Summary NFRAP for IRP Site 21/LF-26 GEPA

22-Oct-99 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 551 Copies of the Draft EE/CA for IRP Site 8/LF-10A, 10B, & 10C 36 CES/CEVR

22-Oct-99 Base Letter to GEPA Regarding Transmittal of Copies the Ikehara, Gregg N. 552 Draft EE/CA for IRP Site 8/LF-10A, 10B, & 10C 36 CES/CEVR

26-Oct-99 GEPA Letter to Base Regarding Comments on Draft EE/CA Wuerch, H. Victor 553 Report for IRP Site 5/LF-7 GEPA

10-Dec-99 GEPA Letter to Base Regarding Comments on Draft EE/CA Salas, Jesus T. 554 for IRP Site 26/FTA-2 GEPA

10-Dec-99 Base Letter to GEPA Regarding Responses to Comments for Ikehara, Gregg N. 555 RVR of IRP Site 39/Harmon Substation, IRP Site 19/LF 24 & 36 CES/CEVR AOCs 1, 2, 3, 4, 5,12, & 22

16-Dec-99 USEPA Region IX Letter to Base Regarding Comments on Ripperda, Mark 556 the Draft RI Report for Harmon Annex USEPA Region IX

23-Dec-99 GEPA Letter to Base Regarding Comments on the Draft Salas, Jesus T. 557 EE/CA Report for IRP Site 8/LF-10A, 10B, & 10C GEPA

01-Jan-00 Final EE/CA for IRP Site 5/LF-7 EA Engineering 558

01-Jan-00 Draft Proposed Plan, Harmon Annex OU 36 CES/CEVR 559

18-Jan-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 560 Copies of Action Memorandum for IRP Site 34/PCB Storage 36 CES/CEVR Area, IRP Site 16/LF-21, IRP Site 10/LF-14, & IRP Site 31/Chemical Storage Area 4

36of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

18-Jan-00 Base Letter to GEPA Regarding Transmittal of Copies of Ikehara, Gregg N. 561 Action Memorandum for IRP Site 34/PCB Storage Area, IRP 36 CES/CEVR Site 16/LF-21, IRP Site 10/LF-14, & IRP Site 31/Chemical Storage Area 4

18-Jan-00 Action Memorandum to Request and Document Approval of the Ikehara, Gregg N. 562 Proposed Removal Action for IRP Site 34/PCB Storage Area 36 CES/CEVR

18-Jan-00 Action Memorandum to Request and Document Approval of the Ikehara, Gregg N. 563 Proposed Removal Action for IRP Site 16/LF-21 36 CES/CEVR

18-Jan-00 Action Memorandum to Request and Document Approval of Ikehara, Gregg N. 564 the Proposed Removal Action for IRP Site 10/LF-14 36 CES/CEVR

18-Jan-00 Action Memorandum to Request and Document Approval of Ikehara, Gregg N. 565 the Proposed Removal Action for IRP Site 31/Chemical Storage 36 CES/CEVR Area 4

27-Jan-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 566 Copies of the Draft Proposed Plan for HIP Sites in the 36 CES/CEVR Harmon Annexes

27-Jan-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 567 Draft Proposed Plan for IRP Sites in the Harmon Annexes 36 CES/CEVR

27-Jan-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 568 Copies of the Draft Final RI Report for IRP Sites in the 36 CES/CEVR Harmon Annexes

27-Jan-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 569 Draft Final RI Report for IRP Sites in the Harmon Annexes 36 CES/CEVR

27-Jan-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 570 Draft Final EE/CA for IRP Site 5/LF-7 36 CES/CEVR

28-Jan-00 RAB Meeting Minutes, 21 Oct 99 EA Engineering 571

31-Jan-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 572 Copies of the Draft Final EE/CA for IRP Site 2/LF-2 36 CES/CEVR

31-Jan-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 573 Draft Final EE/CA for IRP Site 2/LF-2 36 CES/CEVR

01-Feb-00 Final EE/CA for IRP Site 2/LF-2 EA Engineering 574

03-Feb-00 USEPA Region IX Letter to Base Regarding Comments on Ripperda, Mark 575 the Draft EE/CA for IRP Site 8/LF-10 USEPA Region IX

07-Feb-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 576 Draft Final Decision Summary Document for IRP Site 1/LF-1 36 CES/CEVR

37of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

11-Feb-00 Base Letter to Mangilao Mayor Nonito Bias Regarding Scboeck, Edward 577 Termination of Mayor as a RAB Member Colonel, USAF 36 ABW/CV

11-Feb-00 Base Letter to RAB Members Regarding Quarterly RAB Schoeck, Edward 578 Meeting Colonel, USAF 36 ABW/CV

16-Feb-00 RPM Meeting Minutes, 16 Feb 00 EA Engineering 579

18-Feb-00 News Article, "S6M for Cleanup" Loerzel, Adrienne 580 Pacific Daily News

25-Feb-00 GEPA Letter to Base Regarding Comments on Draft RI Salas, Jesus T. 581 Report for Harmon Annex OUs IRP Site 18/LF-23, IRP GEPA Site 19/LF-24 & IRP Site 39/Harmon Substation

28-Feb-00 News Article, "GovGuam Seeks Quick End to Land-Return Loerzel, Adrienne 582 Issue" Pacific Daily News

29-Feb-00 Dept of Interior Letter to Base Regarding Formal Section 7 DiRosa, Roger 583 Consultation for IRP Site 9/LF-13, IRP Site 13/LF-18, IRP GNWR Site 14/LF-19, & IRP Site 15/LF-20

22-Mar-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 584 Copies of the Draft Final NFRAP Report for IRP Site 36 CES/CEVR 28/Chemical Storage Area 1

22-Mar-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 585 Draft Final NFRAP Report for IRP Site 28/Chemical Storage 36 CES/CEVR Area 1

28-Mar-00 Base Letter to USEPA Region IX Regarding Transmittal of Torres, Jess F. 586 Copies of the Draft Final NFRAP Report for IRP Site 17/LF-22 36 CES/CEVR

28-Mar-00 Base Letter to GEPA Regarding Transmittal of Copies of the Torres, Jess F. 587 Draft Final NFRAP Report for IRP Site 17/LF-22 36 CES/CEVR

26-Apr-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 588 Copies of the Draft NFRAP for IRP Site 30/Waste Pile 4 36 CES/CEVR

26-Apr-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 589 Draft NFRAP for IRP Site 30/Waste Pile 4 36 CES/CEVR

02-May-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 590 Final Decision Summary Document of IRP Site l/LF-l 36 CES/CEVR

02-May-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 591 Copies of the Final Decision Summary Document of IRP 36 CES/CEVR Site l/LF-l

38of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

04-May-00 RAB Meeting Minutes, 04 May 2000 EA Engineering 592

09-Jun-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 593 Draft Decision Summary NFRAP for IRP Site 4/LF6 36 CES/CEVR

09-Jun-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 594 Copies of the Draft Decision Summary NFRAP for IRP 36 CES/CEVR Site 4/LF6

22-Jun-00 RPM Meeting Minutes, 22 June 00 EA Engineering 595

03-Aug-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 596 Draft Decision Summary NFRAP for IRP Site 251 Fire 36 CES/CEVR Training Area 1

25-Aug-00 GEPA Letter to Base Regarding GEPA Comments on the Salas, Jesus T. 597 Draft Decision NFRAP for IRP Site 4/LF-6 GEPA

29-Aug-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 598 Draft Final EE/CA Report of IRP Site 8/LFs 10A, 10B, 10C. 36 CES/CEVR

31-Aug-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 599 Copies of the Draft Final EE/CA Decision Summary NFRAP 36 CES/CEVR Report for Site 4/LF-6

31-Aug-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 600 Draft Final Decision Summary NFRAP Report for Site 4/LF6 36 CES/CEVR

31-Aug-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 601 Copies of Final NFRAP Dec. Summ. Rpt for Site 4/LF-6 36 CES/CEVR

31-Aug-00 Base Letter to GEPA Regarding Transmittal of Copies of Ikehara, Gregg N. 602 Final NFRAP Dec. Summ. Rpt for Site 4/LF-6 36 CES/CEVR

07-Sep-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 603 Final Spring Groundwater 2000 Monitoring Report for 36 CES/CEVR MARBO Annex & Northwest Field Operable Units

07-Sep-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 604 Copies of the Final Spring Groundwater 2000 Monitoring 36 CES/CEVR Report for MARBO Annex & Northwest Field Operable Units

15-Sep-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 605 Draft Quality Program Plan & Environmental Cleanup Plan 36 CES/CEVR For Site 24/LF-29 MARBO Operable Unit

15-Sep-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 606 Copies of the Draft Quality Program Plan & Environmental 36 CES/CEVR Cleanup Plan for Site 24/LF-29 MARBO Operable Unit

39of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

22-Sep-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 607 Draft Environmental Cleanup Plan for Site 2/LF-2 Main Base 36 CES/CEVR Operable Units

22-Sep-00 Base Letter to USEPA Region TX Regarding Transmittal of Ikehara, Gregg N. 608 Copies of the Draft Environmental Cleanup Plan for Site 2/LF 2 36 CES/CEVR Main Base Operable Units

03-Oct-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 609 Copies of the Draft Environmental Cleanup Plan for Site 5/LF 7 36 CES/CEVR

03-Oct-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 610 Draft Environmental Cleanup Plan for Site 5/LF 7 36 CES/CEVR

26-Oct-00 USEPA Region IX Letter Regarding EPA Comments on Draft Ikehara, Gregg N. 611 Environmental Cleanup Plan for Site 24/LF 29 and Site 2/LF 2 36 CES/CEVR

01-Nov-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 612 Spring 2000 Groundwater Monitoring Report for Main Base 36 CES/CEVR Operable Units

01-Nov-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 613 Copies of the Spring 2000 Groundwater Monitoring Report for 36 CES/CEVR Main Base Operable Units

06-Nov-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 614 Draft Remedial Verification Report for Site 38/MARBO 36 CES/CEVR Laundry Facility and Site 20/Waste Pile 7 AAFB

06-Nov-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 615 Copies of the Draft Remedial Verification Report for Site 36 CES/CEVR 38/MARBO Laundry Facility and Site 20/Waste Pile 7

06-Nov-00 Base Letter to RAB Members Regarding Next Quarterly Schoeck, Edward 616 Meeting Colonel, USAF 36 ABW/CV

15-Nov-00 RPM Meeting Minutes, 15 November 00 EA Engineering 617

16-Nov-00 RAB Meeting Minutes, 16 Nov 00 EA Engineering 618

16-Nov-00 GEPA Letter to Base Designating Walter Leon Guerrero Salas, Jesus T. 619 as an EPA Representative GEPA

22-Nov-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 620 Final Asphalt Recovery Status Reports for Site 351 Waste 36 CES/CEVR Pile 1 and Site 29/Waste Pile 2

22-Nov-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 621 Copies of the Final Asphalt Recovery Status Reports for Site 36 CES/CEVR 2 35/Waste Pile 1 and Site 29/Waste Pile 2

40of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

22-Nov-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 622 Sampling and Analysis Plan for Remedial Investigation/ 36 CES/CEVR Feasibility Study for Urunao Dumpsites 1 & 2, Urunao Operable Unit, AAFB

22-Nov-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 623 Final Remedial Investigation Report for Harmon Annex 36 CES/CEVR Operable Unit, AAFB

22-Nov-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 624 Copies for the Sampling and Analysis Plan for Remedial 36 CES/CEVR Investigation/Feasibility Study for Urunao Dumpsites 1 & 2, Urunao Operable Unit, AAFB

30-Nov-00 Base Letter to GEPA Regarding Transmittal of Copies of the Ikehara, Gregg N. 625 Final Environmental Cleanup Plan Report for Site 24/Landfill 36 CES/CEVR 29, MARBO Operable Unite, AAFB

30-Nov-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 626 Copies of the Final Environmental Cleanup Report for Site 36 CES/CEVR 24/Landfill 29, MARBO Operable Unit, AAFB

05-Dec-00 Base Letter to GEPA Regarding Transmittal of Copies of for Ikehara, Gregg N. 627 the Amendment of the Record of Decision of the MARBO 36 CES/CEVR Operable Unit

05-Dec-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 628 Copies for the Amendment of the Record of Decision of the 36 CES/CEVR MARBO Operable Unit

13-Dec-00 Base Letter to GEPA Regarding Variances for IRP IRP Ikehara, Gregg N. 629 Basewide QAPP, 3/99 for AAFB 36 CES/CEVR

13-Dec-00 Base Letter to USEPA Region IX Regarding Variances for Ikehara, Gregg N. 630 IRP Basewide QAPP, 3/99 for AAFB 36 CES/CEVR

13-Dec-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 631 Copies for the Draft Proposed Plan for the Harmon 36 CES/CEVR Operable Unit

15-Dec-00 USEPA Region IX Letter to Base Regarding a Request for Ripperda, Mark 632 Variances (13 Dec 00) for IRP Basewide Quality Assurance USEPA Region IX Project Plan (3/99) for AAFB

15-Dec-00 Base Letter to GEPA Regarding Transmittal of Copies for the Ikehara, Gregg N. 633 Final Environmental Cleanup Plan Report for Site 5/LF 7, 36 CES/CEVR Main Base Operable Unit, AAFB

15-Dec-00 Base Letter to GEPA Regarding Transmittal of Copies for the Ikehara, Gregg N. 634 Final Environmental Cleanup Plan Report for Site 2/Landfill 2 36 CES/CEVR

41of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

15-Dec-00 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 635 Copies for the Final Environmental Cleanup Plan Report for 36 CES/CEVR Site 2/Landfill 2, AAFB

15-Dec-00 Base Letter to GEPA Regarding Transmittal of Copies for the Ikehara, Gregg N. 636 Final Environmental Cleanup Plan Report for Site 2/Landfill 2 36 CES/CEVR

16-Jan-01 Base Letter to RAB Members Regarding Quarterly RAB Schoeck, Edward Colonel, 637 Meeting USAF ABW, CV

23-Jan-01 GEPA Letter to Base Regarding Comments on the Record of Salas, Jesus T. 638 Decision Amendment for the MARBO Annex OU Site GEPA 24/Landfill 29

23-Jan-01 GEPA Letter to Base Regarding Comments on the to the Salas, Jesus T. 639 Sampling and Analysis Plan for Remedial Investigation/ GEPA Feasibility Study (RI/FS) for Urunao Dumpsites 1 & 2

24-Jan-01 News Article, "Private Firm to Remove Unexploded Ordnance" Duenas, Joseph E. 640 Guam Variety

06-Feb-01 News Article, "Notice of Availability for Proposed Plan 36 CES/CEVR 641 for the Harmon Annex Operable Unit" Pacific Daily News

07-Feb-01 News Article, "Notice of Availability for Proposed Plan 36 CES/CEVR 642 for the Harmon Annex Operable Unit Pacific Daily News

08-Feb-01 News Article, "Notice of Availability for Proposed Plan 36 CES/CEVR 643 for the Harmon Annex Operable Unit Pacific Daily News

08-Feb-01 Base Letter to GEPA Regarding Transmittal of Copies for Ikehara, Gregg N. 644 the Final Asphalt Removal Report, Site 6/Landfill 8, AAFB 36 CES/CEVR

08-Feb-01 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 645 Copies for the Final Asphalt Removal Report, Site 6/LF 8 36 CES/CEVR

13-Feb-01 Base Letter to RAB Members Regarding the Proposed Plan Ikehara, Gregg N. 646 for the Harmon Annex Operable Unit 36 CES/CEVR

19-Feb-01 News Article, "Public Notice Announcement for the RAB 36 CES/CEVR 647 Meeting and the Proposed Plan for the Harmon Annex Pacific Daily News Operable Unit Meeting

20-Feb-01 News Article, "Public Notice Announcement for the RAB 36 CES/CEVR 648 Meeting and the Proposed Plan for the Harmon Annex Pacific Daily News Operable Unit Meeting

21-Feb-01 RPM Meeting Minutes, 21 Feb 01 EA Engineering 649

42of 43 Andersen AFB, Guam - AR DOCUMENTS Sorted by: Document Date and AR/IR File Number Date of Report: 6 August 2001 DOC. AUTHOR or FILE DATE SUBJECT OR TITLE CORP. AUTHOR NUMBER

21-Feb-01 News Article, "Public Notice Announcement for the RAB 36 CES/CEVR 650 Meeting and the Proposed Plan for the Harmon Annex Operable Pacific Daily News Unit Meeting

21-Feb-01 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 651 Copies for Draft EE/CA for Site 36/Ritidian Dump Site, 36 CES/CEVR Northwest Field Operable Unit

21-Feb-01 Base Letter to GEPA Regarding Transmittal of Copies for the Ikehara, Gregg N. 652 Draft EE/CA for Site 36/Ritidian Dump Site, Northwest Field 36 CES/CEVR Operable Unit

21-Feb-01 Base Letter to GEPA Regarding Transmittal of Copies for the Ikehara, Gregg N. 653 Revision for ARAR's in the MARBO ROD Amendment 36 CES/CEVR

22-Feb-01 Base Letter to USEPA Region IX Regarding Transmittal of Ikehara, Gregg N. 654 the Revised MARBO ROD Amendment 36 CES/CEVR

00-Feb-01 Final Quality Program Plan & Final Environmental Cleanup Arnsfield, Chris 655 Plan for Site 24/Landfill 29 (CD-ROM) IT Corporation

00-Feb-01 Final Quality Program Plan & Final Environmental Cleanup Arnsfield, Chris 656 Plan for Site2/Landfill 2 (CD-ROM) IT Corporation

00-Feb-01 Final Quality Program Plan & Final Environmental Cleanup Arnsfield, Chris 657 Plan for Site 5/Landfill 7 (CD-ROM) IT Corporation

16-Mar-01 Base Letter to EA Engineering Regarding Site 15/LF 20 Poland, D. Joan 658 Natural Resources Clearance 36 CES/CEVR

26-Mar-01 Base Letter to GEPA Regarding Final SAP for RI/FS Ikehara, Gregg N. 659 Urunao Dumpsites 1 & 2, Urunao OU 36 CES/CEVR

27-Mar-01 Base Letter to GEPA Regarding Transmittal of Copies for the Ikehara, Gregg N. 660 Final EE/CA report for Site 8/Landfills 10A, 10B, 10C, 36 CES/CEVR Main Base Operable Unit AAFB

17-May-01 RPM Meeting Minutes, dtd 17 May 01 EA Engineering 661

22-May-01 Base Letter to GEPA Regarding Transmittal of Copies for Ikehara, Gregg N. 662 the Agency Draft Harmon Annex OU Record of Decision 36 CES/CEVR

Bolded items indicate applicability to the Harmon Annex Record of Decision

43 of 43 Appendix B

IRP Sites 19 and 39 Confirmation Sample Results (IT/OHM, 1999) Confirmation Soil Sample Analytical Results for IRP Site 19 Parcel A, Parcel B, and Parcel C Table 2-1 Confirmation Soil Sample Analysis for Parcel A IRP Site 19/Landfill 24, Andersen AFB, Guam

Simple ID HAS19S453 Location Excavaooo Sample Depth (fl bgi) 6 COC Number 58-07 1 HA Sample I>elivery Group Number 98U41 Date Collected , , , , , 28-Dec-98 EPA LPA PkG Res EPA PRG Aoalyte Unjts BTV"' CoDctmratioo Method >D Must01 \ ola tile Orpntc Compound* (VOCi) (ig/ks I260A Acetone NA 1 400.000 6100,000 449 Benzene NA 620 1,400 029 U BromodicbJorome thane NA 980 2,300 030 U 2 BUUBOOC fMcthyl etfayl keione) NA 6900.000 27.000,000 59 U Carbon duuliide NA 350.000 1.200,000 015 U Carbon tetnchlonde NA 230 S20 091 U Chlorobenzenc NA 54.000 180.000 023 U Chloroform NA 2*0 520 049 U Cbloromethane NA 1,200 2.600 24 U Dibromometbane NA NA NA 040 U ! 1 Djcbloroetbeue NA 52 120 062 U cis- 1.2-Didilotoethene NA 42.000 150.000 034 U Ethylbenrene MA 230.000 230.000 045 U 2-Hexanow NA NA NA 14 U Merbylenc chloride NA 8.500 20.000 047 U 4-Methyl-2-pem»none (MIBK) NA NA NA 13 U Naphthalene NA NA NA 046 U 1 1.2.2-TetrachloroethlDe NA 360 870 OJ8 U TeiracbloroeiiieDe (PCE\ NA 4,700 16.000 0.28 U Toluene NA 520.000 520,000 OJ6 U 1 2.3-Tnch)orobaxze« NA NA NA 0.29 U 1 .2 4-Tnchlorobenieoe NA 480,000 1.700,000 0.49 U 1 1 1 -Tnchtoroetbaoe NA 680,000 1,400.000 0.38 U 1 1 J-TncWoroethane NA S20 1,900 0.27 U Tnchtoroetbene NA 2.700 6.100 0.30 U TnchlorofiuorometbjkJie NA 380,000 1300.000 0.33 U Vinyl chlonde NA 21 48 1.2 U m Xylene NA 210,000 210,000 087 U oXylcnc NA 280,000 280,000 0.39 U p- Xylene JLJl*™ 370000 370,000 087 U Nota. CMu Qualifier! NA Not Applicable U The analyie «a§ analyad for. but not detected The anoaaicd nuroencal value u at or below the Method Detection Limit (MDL) PRG denoui Preliminary Remediation Goal 1 The anatyte wv pormvety tdentificxt the quanmanon a as atmumein '" BacifrouiKl Thnahold Value UJ The anafytt H'** analynd for. but not detected- The rqxvud MDL u approximate and may or maty not represent 171 EPA Rdion 9 RendenDil PRG (Mxy. 1991) the actual limn of quanmanon moeoary to aeoamciy ana preaacly meaaurc the analyte m the nanple 01 EPA Rcpon 9 Industrial PRO (May. 1W») B The aoaryte «raa found m an aBaiynMiul biank. Valua in BOLD excead the rcndomal PRG and BTV R The data, are ununMe due to defictenoea m the abtbty to analyze the sample and meet QC emena.

6/11/99 Page I of 3 rbl_2-ljOj Table 2-1 Confirmation Soil Sample Analysis for Parcel A IRP Site 19/Landflll 24, Andersen AFB, Guam

Sample ID HAS19SJ53 Location Excavation Sample Depth (ft bgs) 6 COC Number 58-071 HA Sample Delivery Group Number 98L241 Date Collected 28-Dec-98 EPA EPA PRG Ke« EP* PRG Analyte Units BTV"1 Concentration Method Hi Induct01 Semi-Volanle Organic Compounds (SVOCs) Hg/kg 8270B Aceiupbtbene NA 2.600.000 28.000000 1.200 i_ Acenaphthylene NA NA NA 1.200 t Anthracene NA 14.000000 220.000.000 780 I, Benzo(»>anrhracei]e NA 560 3.600 800 t Benzo(a)pyi«ne NA 56 360 430 U Beozo(b)fluDraxithet>e NA 560 3.600 740 U BenzoOOfluorantbenc NA 5.600 36.000 790 U Benzo(ghl)perylene NA NA NA 470 U Bts(2-ettiylbexyl) phthlaic NA 32.000 210.000 980 I Buryl benzylphthalaie NA 930.000 930.000 880 I Caroazule NA 27.000 150.000 910 U Cbrvwije NA 56.000 360,000 1,000 U Di-D-buryl phthalate NA NA NA 920 U Dibcti2o(aJi)anthr»ccDe NA 56 360 370 L Dibenzofcraa NA 210.000 3700,000 1.200 U Fhwraclbeoe NA 2.000.000 37.000.000 890 U lndeno< 1 .2.3-cd) pyrcnc NA 560 3.600 490 L1 Napbthaiene NA 55,000 190.000 1.600 L Pentacttcropbenol NA 2.500 15.000 920 U Pbeoantfarcoc NA NA NA 760 U Pvrene NA I 500000 26000000 1.000 L1 Polvnucleaj Aromatic Hydrocarbons (PAHs) ug/kg 1310 Anthracene NA 14 000000 220.000.000 1 7 t Fluoraathcne NA 2.000.000 37.000.000 38 L Pyrene NA 1.500.000 26,000.000 23 U Bcnio( i)anthracene NA 560 3.600 32 U Chrysene NA 56,000 360.000 904 j Benzo(b)fluoraarhene NA 560 3.600 4.38 J Bcozo(k)fluoranthe3ie NA 5.600 36.000 3.9 U Bcozo(a)pyicite NA 56 360 3.92 J r*^**»T^« h)BT1t^*rffCCTH' NA 56 360 8 1 U lndeno(!.2.3-cd>pYrene NA S60 3.600 35 U Nora Dua Qualifiers NA Not Applicable U The analyte wa< analyad for. but not detenrd The aiaociatirrl numerical value u at or below the Method Doecoon Limit (MDL) PRG oenoux Preliminary fLrmeshauoci Goal J The analyte waa poainvely idennfied. the quanotanon a an eromaoon '" Background Threihold Value Uj The analyte waa analyzed for, but not i**"--*"*4 The reported MDL u approximate and may or may not reproent "' ETA Rcpon 9 Roidential PRG (May. 199t) the actual limn of cfuanQtabon ""-"nry u> accurately and preciaely measure the analyie m the sample 01 EPA Repon 9 IndumiaJ PRG (May. 199!) B The analyie waa found in an adeemed blank. Values m BOLD exceed the residential PRG and BTV R The data are unuaable due to ocficicnoef in the ability to analyze the sample and meet QC criteria.

Pa|e2of3 tbl 2-l.xls Table 2-1 Confirmation Soil Sample Analysis for Parcel A IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HAS39S450 HAS39S451

Dwxm Hoi Spot- Same Location Excavation UEA04S19S023

Sample Depth (fl bgs) 15 6 COC Number 58-06 7HA 58-067HA Sample Delfverv Group Number 47581 47581 Date Collected 21 D«-9B 23 D«-9S EPA Anilyu Units .... Subsurface Cle»D-lp Goal Co»ceDtn.ftoe Metnoo Dioxins liE'kj 8290 Total WHO TEQ 1 0 00164 000160 Notes Dau Qualifiers NA Not Applicable U The analyte was analyzed for. but not detected The associated numenca! value is at or below tie MDL 1 The BDtiyte was positively identified, the quanatanon u as estimation UJ The anajyte was analyzed for. but not delected Tbe reported MDL is approximate and may or may not represent the actual limit of quantiuuxm necessary to accurately and precisely measure tbe analyte u> tbe sample B Tbe aaaJyte was found m an associated blank, u well u in the sample R Tbe data are unusable due to deficiencies m tbe abiluy to analyze toe sample and meet QC cnteru

6/11/99 Pa(e3of3 tbl 2-l.xh Table 2-2 Confirmation Soil Sample Analysis for Parcel B IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HAS39S413 HAS39S414

Dioxin Hot Spot - Same Dioxin Hot Spot - Same Location as EA04S19S019 •SEA04SI9S032

Sample Depth (ft bgs) 45 5 COC Number 58-063 HA 58-063HA Sample Delivery Group Number 48480 48480 Date Collected !2-Dec-98 !2-Dec-98 EPA Analyte Units Concentration Method Dioxins UK/kg 8290 Total WHO TEQ 0.0006 00005

Data Qualifiers. U The analyie was analyzed for, but not detected The associated numerical value is at or below the method detection limit (MDL).. 1 The analyte was positively identified; the quanlitalion ij an estimation. UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The analyie was found in an associated blank, as well u in the sample. R The data are unusable due to deficiencies in the ability to analyze the sample and meel QC criteria.

6/11/99 Page I of I •M 2-2 xls Table 2-3 Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HAS19S537 HASI9S538 IIASI9S539 HAS19S540 HASI9S54I Location Excavation Floor Excavation Floor Excavation Floor Excavation Floor Excavation Floor Sample Depth (R bgs) 5.0 50 50 50 50 COC Number 58-083HA 58-083HA 58-083HA 58-083HA 58-083HA Sample Delivery Group Number 99B07I 99B07I 99B071 99B07I 99B07I Date Collected 05-Feb-99 05-Feb-99 05-Feb-99 05-Feb-99 05-Feb-99

EPA (|) EPA PKG EPA PRG Analyte Units Concentration Method BTV Res'" Indust"1 Metals rug/kg 601 OA Antimony 63 30 750 4.4 U 4.2 U 4.2 U 906 J 4.3 U Lead 166 400 1,000 24.3 6.77 4.78 387 5.28

Notes: Data Qualifiers: NA Not Applicable U The analyie was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL). PRG denotes Preliminary Remediation Goal } The analyte was positively identified; the quantitation is an estimation. "'Background Threshold Value UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. |J'EPA Region 9 Industrial PRG (May, 1998) B The analyte was found in an associated blank. Values in BOLD exceed the residential PRG and BTV R The data are unusable due to deficiencies in the ability to analyze (he sample and meet QC criteria. S Applied to all field screening data.

6/11/99 Page I of 7 tbl 2-3 xls Table L-A Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HASI9S542 HAS19S543 HASI9S544 HASI9S545 HASI9S546 Location Excavation Floor Excavation Floor Excavation Floor Excavation Floor Excavation Floor Sample Depth (ft bgs) 50 5.0 5.0 5.0 5.0 COC Number 58-083HA 58-083HA 58-083HA 58-083HA 58-083HA Sample Delivery Group Number 99B07I 99B07I 99B07I 99B07I 99B07I Date Collected 05-Fcb-99 05-Feb-99 05-Feb-99 05-Feb-99 05-Feb-99 EPA EPA PRG EPA PRG Analyte Units BTV'" Concentration Metbod Res'" Indiist"' Metals mi/kj 6010 A Antimony 63 30 750 5.23 J 4.3 U 4.4 U 626 J 43 U Lead 166 400 1,000 24.3 45.6 5.07 47.9 26.6

Notes: Data Qualifiers: NA Not Applicable U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL). PRG denotes Preliminary Remediation Goal 1 The analyte was positively identified; the quantitation is an estimation. 10 Background Threshold Value UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May. 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. (J|EPA Region 9 Industrial PRG (May. 1998) B The analyte was found in an associated blank. Values in BOLD exceed the residential PRG and BTV R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to all field screening data.

6/11/99 I'agc 2 of 7 ihl 2 3 xls Table 2-3 Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HAS19S547 HASI9S548 HASI9S549 HASI9S550 HASI9S55I Duplicate of Location Excavation Floor Excavation Floor North Wall North Wall HASI9S537 Sample Depth (ft bgs) 5.0 50 50 2.5 25 COC Number , 58-084I1A 58-084HA 58-084HA 58-084HA 58-084HA Sample Delivery Group Number 99B07I 99B07I 99B07I 99B07I 99B071 Date Collected 05-Feb-99 05-Feb-99 05-Feb-99 05-Feb-99 05-Feb-99 EPA EPA PRG EPA PRG Analyte Ualti BTV"» Concentration Method Res'" Indust01 Metals tug/kg 60IOA Antimony 63 30 750 4.1 U 4.2 U 43 U 4.1 U 5.9 J Lead 166 400 1,000 5.21 21.3 17.7 15.6 27.8

Notes: Data Qualifiers: NA Not Applicable U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified; the quantitation is an estimation. '"Background Threshold Value UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. "'EPA Region 9 Industrial PRG (May, 1998) B The analyie was found in an associated blank. Values in BOLD exceed the residential PRG and BTV R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to all field screening data.

6/11/99 I'age 3 of 7 (hi 2-3 xls Table 2-3 Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HAS19S552 HASI9S553 HAS19S554 HASI9S555 HAS19S556 Location East Wall East Wall South Wall South Wall West Wall Sample Depth (ft bgs) 2.5 2.5 2.5 2.5 2.5 COC Number 58-084 HA S8-084HA 58-084HA 58-084HA 58-084HA Sample Delivery Group Number 99B07I 99B071 99B07I 99B07I 99B07I Date Collected 05-Feb-99 05-Feb-99 05-Feb-99 05-Fcb-99 05-Feb-99 EPA EPA PHG EPA PKG Analyte Units BTV'" Concentration Method Res111 Indiiil'" Metals mg/kg

Antimony L 63 30 750 4.1 U 4.7 U 4.3 U 278 183 Lead 166 400 1,000 50.5 50.2 43.6 998 83)

Notes. Data Qualifiers: NA Nol Applicable x U The analyte was analyzed for, but not detected The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified, the quantitation is an estimation. '''Background Threshold Value UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample "'EPA Region 9 Industrial PRG (May. 1998) B The analyte was found in an associated blank Values in BOLD exceed the residential PRG and BTV R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to all field screening data

6/11/99 Cage 4 of 7 Ibl 2 3 xls Table 2-J Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HASI9S557 HAS19S558 HAS19S590 HAS19S59I HAS19S592 Duplicate of Location West Wall Excavation Floor Excavation Floor Excavation Floor HASI9S554 Sample Depth (ft bgs) 2.5 25 50 50 50 COC Number 58-085HA 58-085HA 58-091 HA 58-091 HA 58-091 HA Sample Delivery Group Number 99B071 99B07I 99E006 99E006 99E006 Date Collected ' 05-Feb-99 05-Feb-99 26-Apr-99 26-Apr-99 26-Apr-99 EPA EPA PRG EPA PRG Anilyle Units BTV'" Concentration Method Res'" Indus! '" Metals mg/kg 60IOA Antimony 63 30 750 32.2 4.2 U 4.6 U 4.4 U 43 U Lead 166 400 1,000 1,140 85 37.7 J 56.4 J 147 J

Notes: Data Qualifiers: NA Not Applicable U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL), PRG denotes Preliminary Remediation Goal i The analyte was positively identified; the quantitation is an estimation. "'Background Threshold Value UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. "'F.PA Region 9 Industrial PRG (May, 1998) B The analyte was found in an associated blank. Values in BOLD exceed the residential PRG and BTV R The data are unusable due lo deficiencies in the ability to analyze the sample and meet QC criteria S Applied to all field screening data

6/11/99 Page 5 of 7 tbl 2-3 xls Table 2-3 Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample (D HASI9S593 HAS19S594 HAS19S595 HASI9S596 HASI9S597

Location Excavation Floor Excavation Floor North Wall West Wall West Wall

Sample Depth (ft bgi) 5.0 5.0 2.5 25 2.5 COC Number 58-091 HA 58-091 HA 58-091 HA 58-091 HA 58-091 HA Sample Delivery Group Number 99E006 99E006 99E006 99E006 99E006 Date Collected 26-Apr-99 26-Apr-99 26-Apr-99 26-Apr-99 26-Apr-99 EPA EPA PRG EPA PRG Analyte Unlti BTV '" Concentration Method Re,'" Indus! '" Melall mg/kg 6010A Antimony 63 30 750 4.4 U 4.3 U 5.3 U 4.7 U 5.2 U Lead 166 400 1,000 18.2 J 32.9 J 63.5 J 82.9 J 65.3 J

Notes: Data Qualifiers: NA Not Applicable U The analyte was analyzed for, but not detected The associated numerical value is at or below the Method Detection Limit (MDL). PRG denotes Preliminary Remediation Goal J The analyte was positively identified; the quantitalion is an estimation. "'Background Threshold Value UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. (J) EPA Region 9 Industrial PRO (May, 1998) B The inalyte was found in an associated blank Values in BOLD exceed the residential PRG and BTV R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to all field screening data.

6/11/99 Page 6 of 7 Ibl 2 3 xls Table 2-3 Confirmation Soil Sample Analysis for Parcel C IRP Site 19/Landfill 24, Andersen AFB, Guam

Sample ID HASI9SS98 HASI9S599 HASI9S600 HASI9S60I Duplicate of Location South Walt Excavation Floor South Wall HAS39S596 Sample Depth (ft bgi) 2.5 2.5 5.0 2.5 COC Number 58-091 HA 58-091 HA 58-092HA 58-092HA Sample Delivery Group Number 99E006 99E006 99E006 99E006 Date Collected 26-Apr-99 26-Apr-99 26-Apr-99 26-Apr-99 EPA EPA PRG EPA PRG Analyte Unlla BTV"> Concentration Method Res'" Indus! "' Metals nig/kg M10A Antimony . 63 30 750 4.9 U 4.6 U 4.4 U 5,1 U Lead 166 400 1,000 184 J 72.6 J 65.3 J 61.2 J

Notes: Data Qualifiers: NA Not Applicable U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL). PRG denotes Preliminary Remediation Goal J The analyie was positively identified; the quantitation is an estimation. '"Background Threshold Value U) The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent "'EPA Region 9 Residential PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. "' EPA Region 9 Industrial PRG (May. 1998) B The analyte was found in an associated blank. Values in BOLD exceed the residential PRO and BTV R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to all field screening data.

6711/99 Page 7 of 7 tbl 2-3 xls Confirmation Soil Sample Analytical Results for IRP Site 39 Oil/Water Separator

Confirmation Soil Sample Analytical Results for IRP Site 39 PAH "Hot Spots" Table 2-2 Confirmation Soil Sample Analysis for the PAH Hot Spot at "A6" IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S291 HAS39S292 Location Excavation Excavation Sample Depth bgs (feet) 10 10 COC Number 58-048HA 58-048HA Sample Delivery Group Number 981110 981110 Date Collected 14-Sep-98 14-Sep-98 EPA EPA PRG EPA PRG Analyte Units Concentration Method Res'" Indict"1 Polynuclear Aromatic 8310 Hydrocarbons (PAHs) MB/kg Anthracene 14,000,000 220,000,000 18 U 17 U Fluoranthene 2,000,000 37,000,000 40 U 39 U Pyrene 1,500,000 26,000,000 25 U 24 U Benzo(a)anthracene 560 3,600 34 U 33 U Chrysene 56,000 360,000 24 U 24 U Bcnzo(b)fluoranlhene 560 3,600 694 J 43 U Benzo(k)fluoranthene 5,600 36,000 42 U 4 1 U Benzo(a)pyrene 56 360 30 U 29 U

Dibenzo(a,h)anthracene 56 1 360 87 U 84 U lndeno( 1 ,2,3-cd)pyrene 560 3,600 37 U 36 U Ohmicron Field Screen r>g"

Page I of I 9im'>R\RIRPSilc39 Table 2-3 Confirmation Soil Sample Analysis for tbe PAH Hot Spot at "C2" IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S293 HAS39S294 HAS39S295 HAS39S296 HAS39S297 Location Excavation Excavation Excavation Excavation Excavation Sample Depth bgs (feet) 10 1 0 10 1.0 1 0 COC Number 58-048HA 58-048HA 58-048HA 58-048HA 58-048HA Date Collected ll-Sep-98 ll-Sep-98 ll-Sep-98 ll-Sep-98 ll-Sep-98 EPA EPA PRG Res EPA PRG Analyte Units BTV'" Concentration Method (J) Indust (3) Polynuclear Aromatic Mg/kg 8310 Hydrocarbons (PAHs) Anthracene NA 14.000,000 220,000,000 1.7 U 1.7 U 1 7 U 1.7 U 1.8 U Fluoranthene NA 2.000,000 37,000,000 3.8 U 3.9 U 39 U 3.9 U 40 U Pyrene NA 1,500,000 26,000,000 24 U 4.82 i 24 U 2.4 U 2.5 U Benzo(a)anthracene NA 560 3,600 3.2 U 32 U 3.2 U 3.3 U 34 U Chrysene NA 56,000 360.000 2.3 U 2.4 U 2.4 U 2.4 U 2.4 U Benzo(b)fluoranthene NA 560 3,600 43 U 43 U 43 U 4.3 U 4.5 U Benzo(k)fluoranthene NA 5,600 36,000 4.0 U 40 U 40 U 40 U 42 U Benzo(a)pyrene NA 56 360 29 U 29 U 29 U 29 U 30 U Dibenzo(a,h)anthracene NA 56 360 8.3 U 83 U 83 U 84 U 86 U Indeno(l,2,3-cd)pyrene NA 560 3,600 3.5 U 3.6 U 36 U 36 U 37 U Ohmicron Field Screen ug/kg NA NA NA NA 32 S 32 S 120 S 110 S 39 S

Notes. Data Qualifiers: NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the MDL '"' Background Threshold Value J The analyte was positively identified, the quantitation is an estimation '-' EPA Region 9 Residential PRG (May, 1998) W The analyte was analyzed for, but not delected. The reported MDL is approximate and may or may not represent "' EPA Region 9 Industrial PRG (May. 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PRG. B The analyte was found in an associated blank, as well as in the sample R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to oilfield screening data

9I9&S9/RVR IRP Site 39 I'age I of 2 Table 2-3 (continued) Confirmation Soil Sample Analysis for the PAH Hot Spot at "C2" IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S298 HAS39S299 HAS39S300 HAS39S301 1IAS39S30S Location Excavation Excavation Excavation Excavation Dup of -300 Sample Depth bgs (feet) t 0 10 10 1 0 10 COC Number 58-048HA 58-048HA 58-048HA 58-049HA 58-049HA Date Collected ll-Sep-98 ll-Sep-98 ll-Sep-98 1 1 -Scp-98 l,l-Sep-98 EPA EPA PRG Res EPA PRG Analyie Units BTV'" Concentration Method a> Indusl (3> Polynuclear Aromatic ug/kg 8310 Hydrocarbons (PAHs) Anthracene NA 14.000.000 220.000,000 17 U 19 U 19 U 1.9 U 39 U Fluoranthene NA 2.000,000 37,000,000 3.9 U 325 ) 28.1 J 19.7 J 8.7 U Pyrene NA 1,500,000 26,000,000 2.4 U 302 J 37.6 J 2.7 U 54 U Benzo(a)anthracene NA 560 3,600 33 U 461 24.4 r~ 154 961 J Chrysene NA 56,000 360,000 2.4 U 271 J 14.9 J 2.6 U 53 U Benzo(b)fluoranthene NA 560 3,600 4.4 U 53.8 289 136 J 185 J Bcnzo(k)fluoranthene NA 5,600 36,000 4.1 U 37.0 24.9 13.3 J 9 1 U Benzo(a)pyrcne NA 56 360 3.0 U 58.4 43.4 21.4 23 J Dibenzo(a,h)anthracene NA 56 360 8.4 U 9.3 U 94 U 9.4 U 19 U Indeno( 1 ,2,3-cd)pyrene NA 560 3,600 36 U 67.9 39.2 J 17.8 J 22.4 J Ohmicron Field Screen ue/ke NA NA NA NA 46 S 210 S 390 S 210 S NA

Notes: Data Qualifiers: NA Not Applicable I Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the MDL. "' Background Threshold Value J The analyie was positively identified, the quantitation is an estimation. '" EPA Region 9 Residential PRG (May, 1998) UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent {" EPA Region 9 Industrial PRG (May. 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. Values in BOLD exceed the residential PRG. B The analyte was found in an associated blank, as well as in the sample R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to oilfield screening data.

9196?' ''R IRP Site 39 •c2of2 Table 2-4 Confirmation Soil Sample Analysis for the PAH Hot Spot at "E6" IRP Site 39/Harmon Substation. Andersen AFB, Guam Sample ID HAS39S302 HAS39S303 HAS39S304 Location Excavation Excavation Duplicate of -303 Sample Depth bgs (reel) 10 1.0 1.0 COC Number 58-049HA 58-049HA 58-049HA Sample Delivery Group Number 981110 981110 981110 Dale Collected 14-Sep-98 14-Sep-98 14-Sep-98 EPA EPA PRG Res EPA PRG Analyte Units Concentration Method

Notes: Data Qualifiers: bgs denotes below ground surface U The analyte was analyzed for, but not detected. The associated numerical value is at or below the NA Not Applicable I Not Analyzed Method Detection Limit (MDL). PRG Denotes Preliminary Remediation Goal J The analyte was positively identified; the quantitation is an estimation. '" EPA Region 9 Residential PRG (May. 1998) UJ The analyie was analyzed for, but not detected. The reported MDL is approximate and may or may not (" EPA Region 9 Industrial PRG (May. 1998) represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PRG B The analyie was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to oilfield screening data

<)|%S():R\R IRP Site 39 Page 1 of I Confirmation Soil Sample Analytical Results for IRP Site 39 Buried Drum Area Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S241 HAS39S242 HAS39S243 HAS39S244 HAS39S245 Location Excavation Floor Excavation Floor Excavation Floor Excavation Floor Excavation Floor Sample Depth bgs (feet) 10 10 10 10 10 COC Number 58-039HA 58-039HA 58-039HA 58-0391 IA 58-039HA Sample Delivery Group Number 981003 981003 981003 981003 981003 Date Collected 28-AUR-98 28-Aug 98 28-Aug-98 28-Aug 98 28-Aue 98 EPA EPA PRG EPA PRG Analyte Units Concentration Method Res'" Indust m Polychiorinated Biphenyls Mg/kg 8081 (PCBs) Aroclor 1016 NA NA 79 U 79 U 79 U 79 U 79 U Aroclor 1221 NA NA 78 U 78 U 78 U 78 U 78 U Aroclor 1232 NA NA 78 U 78 U 78 U 78 U 78 U Aroclor 1242 NA NA 28 U 28 U 28 U 28 U 28 U Aroclor 1248 NA NA 47 U 47 U 47 U 47 U 47 U Aroclor 1254 NA NA 31 U 31 U 3 1 U 3 1 U 3 1 U Aroclor 1 260 NA NA 49 U 49 U 49 U 49 U 49 U Total PCBs 200 1,300 Notes Data Qualifiers NA Not Applicable /Not Analyzed U The analyte was analyzed for, but not detected The associated numerical value is at or below the Method Detection Limn (MDL) PRG denotes Piehmtnary Remediation Goal J The analyte was positively identified, the quantitation is an estimation '" EPA Region 9 Residential PRG (May. 1998) UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent '•' EPA Region 9 Industrial PRG (May. 1998) the actual limit ofquantilation necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PRG S Applied to oilfield screening data

91%89/RVRIRPSitc Page 2 of 10 Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S251 HAS39S252 11AS39S2S3 HAS39S254 Location East Wall East Wall South Wall South Wall Sample Depth bgs (feet) NA NA NA NA COC Number 58-040HA 58-040HA 58-040HA 58 040HA Sample Delivery Group Number 981003 981003 981003 981003 Date Collected 28-Aug 98 28-Aug-98 28 Aug 98 28 Aug 98 EPA EPA PRG EPA PRG Analyte Units Concentration Method Res'" Indust"1 Polychiorinated Bipbenyls ug/kg 8081 (PCBs) Aroclor 1016 NA NA 79 U 79 U 79 U 79 U Aroclor 1221 NA NA 78 U 78 U 78 U 78 U Aroclor 1232 NA NA 78 U 78 U 78 U 78 U Aroclor 1242 NA NA 28 U 28 U 28 U 28 U Aroclor 1248 NA NA 47 U 47 U 47 U 47 U Aroclor 1254 NA NA 31 U 31 U 31 U 3 1 U Aroclor 1260 NA NA 49 U 49 U 49 U 49 U Total PCBs 200 1,300 Notes Data Qualifiers NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not delected The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified, the quantitation is an estimation {" EPA Region 9 Residential PRG (May, 1998) UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent '-' EPA Region 9 Industrial PRG (May, 1998) the actual limit of quant station necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PKO S Applied to oilfield screening data

R IRP Site P- Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S373 HAS39S374 HAS39S375 HAS39S376 HAS39S377 Location Excavation Floor Excavation Floor Excavation Floor Excavation Floor Excavation Floor Sample Depth bgs (feet) 14 14 14 14 14 COC Number 58 055HA 58-055HA 58 055HA 58 055HA 58 055HA Sample Delivery Group Number 98J147 98JI47 98J147 98JI47 98JI47 Date Collected 20-Oct-98 20 Oct 98 20-Oct 98 20-Oct-98 20 Oct 98 EPA EP\ PRG EPA PRG Analyte Units Concentration Method Res'" litdust1" Polynuclear Aromatic ug/kg 8310 Hydrocarbons (PAHs) Anthracene 14,000,000 220,000.000 17 U 17 U 16 U 17 U 1 7 U Fluoranthene 2,000,000 37,000,000 38 U 38 U 37 U 38 U 37 U Pyrene 1,500,000 26.000,000 24 U 23 U 23 U 24 U 23 U Benzo(a)anthracenc 560 3,600 32 U 32 U 31 U 32 U 32 U Chrysene 56,000 360,000 23 U 23 U 22 U 23 U 23 U Benzo(b)fluoranthene 560 3,600 42 U 42 U 4 1 U 43 U 42 U Benzo(k)fluoranlhene 5,600 36,000 40 U 39 U 38 U 40 U 39 U Benzo(a)pyrene 56 360 29 U 28 U 28 U 29 U 28 U Dibenzo(a,h)anthracene 56 360 82 U 81 U 80 U 83 U 8 1 U lndeno( 1 ,2,3-cd)pyrene 560 3,600 35 U 34 U 34 U 35 U 34 U Ohmicron Field Screen MR/kg NA NA NA 130 S 20 US 20 US 32 S 20 US Notes Data Qualifiers NA Not Applicable / Not A nalyzed U The analyte was analyzed for, but not detected The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified, the quantitation is an estimation '" EPA Region 9 Residential PRG (May. 1998) UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent '-' EPA Region 9 Industrial PRG (May. 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PRG B The analyte was found m an associated blank R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to oilfield screening data

IRP Site •! of 10 Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S378 HAS39S379 HAS39S380 HAS39S38I HAS39S572 Location Excavation Floor Excavation Floor Excavation Floor Excavation Floor North Wall Sample Depth bgs (feet) 14 14 14 14 5 to 10 COC Number 58-055HA 58-055HA 58-055HA 58-055HA 58-089HA Sample Delivery Group Number 98J147 98JI47 98J147 98JI47 99D124 Date Collected 20-Oct-98 20-Oct-98 20-Oct-98 20-Oct-98 21-Apr-99 EPA EPA PRG J EPA PRG Analyte Units Concentration Method Res'" I Indust'2' Polynuclear Aromatic 8310 Hydrocarbons (PAHs) Mg/kg Anthracene 14,000.000 220,000,000 1.7 U 16 U 1.6 U 1.6 U 1 6 U Fluoranthene 2,000,000 37,000,000 3.7 U 3.7 U 37 U 36 U 24.4 i Pyrene 1,500,000 26,000,000 L-— 2i__JI 23 U 2.3 U 2.3 U 50.6 J Benzo(a)anthracene 560 3,600 3.2 U 3 1 U 31 U 3.1 U 289 J Chrysene 56,000 360,000 2.3 U 23 U 2.2 U 2.2 U 182 1 Benzo(b)fluoranlhene 560 3,600 4.2 U 41 U 4 1 U 41 U 58.9 J - Benzo(k)fluoranthene 5,600 36,000 3.9 U 39 U 38 U 3.8 U 10! J Bcnzo(a)pyTene 56 360 2.8 U 2.8 U 28 U 28 U 554 J Dibenzo(a,h)anlhracene 56 360 8.1 U 80 U 80 U 7.9 U 3.64 J lndeno(l ,2,3-cd)pyrene 560 3,600 3.4 U 34 U 34 U 34 U 41 2 J Ohmicron Field Screen ug/kg NA NA NA 20 US 25 S 20 US 20 US 20 US' Notes: Data Qualifiers. NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified; the quantitalion is an estimation '" EPA Region 9 Residential PRG (May. 1998) UJ The analyte was analyzed for. but not detected. The reported MDL is approximate and may or may not represent '•" EPA Region 9 Industrial PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PRG B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to all field screening data

•)!%>•'" 'R IRP Sue 5 of 10 Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S575 HAS39S576 HAS39S578 HAS39S580 HAS39S581 Location North Wall East Wall East Wall South Wall South Wall Sample Depth bgs (feet) 1 to 5 5to 10 5 to 10 5lo 10 1 to 5 COC Number 58-089HA 58-089HA 58 089HA 58-089HA 58 089HA Sample Delivery Group Number 99DI24 99D124 99DI24 99DI24 99DI24 Dale Collected 21-Apr-99 21-Apr-99 2l-Apr-99 21 -Apr 99 2l-Apr-99 EPA EPA PRG EPA PRG Analyte Units Concentration Method Res'" Indus!m Polynuclear Aromatic PR/kg 8310 Hydrocarbons (PAHs) Anthracene 14,000,000 220,000,000 274 J 1 6 U 17 U 1 7 U 17 U Fluoranthene 2,000,000 37,000,000 127 J 36 U 38 U 38 U 194 J Pyrene 1,500,000 26,000,000 124 J 22 U 24 U 23 U 324 J Benzo(a)anthracene 560 3,600 716 30 U 32 U 32 U 207 Chrysene 56,000 360,000 496 J 22 U 23 U 23 U 133 ) Benzo(b)fluoranthene 560 3,600 89 40 U 42 U 42 U 28 Benzo(k)fluoranthene 5,600 36,000 41 1 38 U 40 U 39 U 133 Benzo(a)pyrene 56 360 77.5 27 U 29 U 29 U 251 Dibenzo(a,h)anthracene 56 360 92 U 78 U 82 U 82 U 84 U lndeno(l ,2,3-cd)pyrene 560 3,600 796 33 U 35 U 35 U 262 J Notes Data Qualifiers NA Not Applicable / Not A nalyzed U The analyie was analyzed for, but not delected Tlie associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified, the quantitation is an estimation '" EPA Region 9 Residential PRG (May. 1998) UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent "' EPA Region 9 Industrial PRG (May. 1998) the actual limit of quantitation necessary to accurately and precisely measure the analvte in the sample Values in BOLD exceed the residential PRG B The analyte was found in an associated blank R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria

R\R IRP sue Pai>e6of 10 Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S582 HAS39S583 I1AS39S607 HAS39S608 HAS39S609 Location South Wall South Wall West Wall West Wall West Wall Sample Depth bgs (feet) 5to 10 1 to 5 4 4 NA COC Number 58-090HA 58-090HA 58 094 HA 58-094HA 58-094HA Sample Deliver) Group Number 99DI24 99D124 99E027 99E027 99E027 Date Collected 21-Apr-99 21-Apr-99 05 May-99 05-May-99 05-May-99 EPA EP4 PRG EPA PRG Analyte Units Concentration Method Res'" Indust I2) Polynuclear Aromatic ug/kg 8310 Hydrocarbons (PAHs) Anthracene 14,000,000 220,000,000 1 7 U 1 7 U 1 6 U 1 7 U 16 U Fluoranthene 2,000,000 37,000,000 41 1 J 71 8 J 37 U 38 U 36 U Pyrene 1,500,000 26,000,000 396 J 62 J 18 J 23 U 22 U Bcnzo(a)anlhracene 560 3,600 212 517 18 32 U 31 U Chrysene 56,000 360,000 147 J 385 i 10 J 23 U 22 U Benzo(b)fluoranlhene 560 3,600 309 869 26 42 U 40 U Benzo(k)fluoranthene 5,600 36,000 138 389 16 40 U 38 U Benzo(a)pyrene 56 360 259 87.5 27 29 U 27 U Dibenzo(a,h)anthracene 56 360 82 U 638 J 79 U 82 U 78 U !ndeno(l ,2,3-cd)pyrene 560 3,600 197 J 80 30 J 35 U 33 U Notes Data Qualifiers NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not delected The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified, the quantilatwn is an estimation '" EPA Region 9 Residential PRG (May. 1998) UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent '•' EPA Region 9 Industrial PRG (May, 1998) the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample Values in BOLD exceed the residential PRG B The analyte was found in an associated blank R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria

H IRP Site 7 of 10 Table 2-6 Confirmation Soil Sample Analysis for the Buried Drum Area IRP Site 39/Harmon Substation, Andersen AFB. Guam Sample ID HAS39S610 HAS39S6II HAS39S612 HAS39S613 HAS39S6I4 Location West Wall North Wall North Wall Easl Wall East Wall Sample Depth bgs (feet) NA 2.5 2.5 2.5 2.5 COC Number 58-094HA 58-095HA 58-095HA 58-095ilA 58-095HA Sample Delivery Group Number 99E027 99E049 99E049 99E049 99E049 Date Collected 05-May-99 06-May-99 06-May-99 06-May-99 06-May-99 EPA EPA PRG EPA PRG Analyte Units Concentration Method Res'" Indust (1) Polynuclear Aromatic ug/kg 8310 Hydrocarbons (PAHj) Anthracene 14.000.000 220,000,000 1.6 U 17 i 1.7 U 1.6 U 1 8 U Fluoranthene 2.000,000 37,000,000 3.6 U 210 3.8 U 12 J 140 J Pyrenc 1,500,000 26,000,000 2.3 U 110 J 2.4 U 97 J 98 J Benzo(a)anthracene 560 3,600 3.1 U 53 3.2 U 58 J 60 Chrysene 56,000 360,000 2.2 U 27 J 2.3 U 3.7 J 34 ) Benzo(b)fluoranthene 560 3,600 4.1 U 46 43 U 74 J 69 Benzo(k)fluoranthene 5,600 36,000 3.8 U 28 4.0 U 6.1 J 41 Benzo(a)pyrene 56 360 2.8 U 47 2.9 U 8.3 J 79 Dibenzo(a,h)anthracene 56 360 7.9 U 8.2 U 8.2 U 8.0 U 85 U lndeno( 1 ,2,3-cd)pyrene 560 3,600 34 U 45 3.5 U 34 U 70 Notes. Data Qualifiers: NA Not Applicable / Not Analyzed^ U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL) PRG denotes Preliminary Remediation Goal J The analyte was positively identified; the quantitation is an estimation. '" EPA Region 9 Residential PRG (May, 1998) UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent '-' EPA Region 9 Industrial PRG (May. 1998) the actual limit ofquantilation necessary to accurately and precisely measure the analyie in the sample Values in BOLD exceed the residential PRG B The analyie was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria.

91%8'J'RVR IRP Site Page 8 of 10 Table 2-6 (continued) Confirmation Soil Sample Analysis for Buried Drum Area, IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S241/2 HAS39S243/4 HAS39S245/6 HAS39S247/8 HAS39S249/50 Location Excavation Floor Excavation Floor Excavation Floor West Wall North Wall Sample Depth bgs (feet) 10 10 10 NA NA COC Number 58-041 HA 58-041 HA 58-041 HA 58-041 HA 58-041 HA Sample Delivery Group Number 46643 46643 46643 46643 46643 Date Collected 28-Aug-98 28-Aug-98 28-Aug-98 28-Aug-98 28-Aug-98 EPA Subsurface Clean- Analyte Units Concentration Method lip Goat Dioxins Cg/kg 8290 Total WHO TEQ 1.0 0.0081 0.0098 I 0 0052 0 0059 | 0.0052 Notes: Data Qualifiers: NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not delected. The associated numerical value is at or below the Method Detection Limit (MDL). J The analyie was positively identified, the quantitation is an estimation. W The analyie was analyzed for, but not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria

9l9689/RVRIRPSile39 0 of 10 Table 2-6 (continued) Confirmation Soil Sample Analysis for Buried Drum Area, IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S251/2 11AS39S253/4 HAS39S255 Location East Wall South Wall Dupof-241/2 Sample Depth bgs (feel) NA NA 10 COC Number 58-041 HA 58-041 HA 58-041HA Sample Delivery Group Number 46643 46643 46643 Date Collected 28-Aug-98 28-Aug-98 28-Aug-98 EPA Subsurface Clean- Analyte Units Concentration Method Up Goal Dioxins wg/kg 8290 Total WHO TEQ 1.0 0.0063 0.0059 | 0.0099 Notes: Data Qualifiers: NA Not Applicable /Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL). J The analyte was positively identified; the quantitation is an estimation. UJ The analyte was analyzed for, bat not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria.

9!%89/RVRlRPSile39 Page I Oof 10 Confirmation Soil Sample Analytical Results for IRP Site 39 Miscellaneous Container Area

Soil Sample Analysis Results for IRP Site 39 Site Wide Dioxin Sampling Table 2-8 Soil Sample Analysis for the Site Wide Dioxin Sampling IRP Site 39/Harmon Substation. Andersen AFB, Guam Sample ID HAS39S153 HAS39S154 HAS39S155 HAS39S156 HAS39S157 Site 39 Harmon Site 39 Harmon Site 39 Harmon Site 39 Harmon Location Dupof-153 Substation Substation Substation Substation Sample Depth bgs (feet) 0.1-0.3 0.1-0.3 0.1-0.3 0.1-0.3 0.1-0.3 COC Number 58-026HA 58-026HA 58-026HA 58-026HA 58-026HA Sample Delivery Group Number 46267 46267 46267 46267 46267 Date Collected 16-Jul-98 16-Jul-98 17-Jul-98 17-Jul-98 17-Jul-98 EPA Analyte Units Concentration Method Dioxins Ug/l(g 8290 Total EPA TEQ 0.00921 0.01727 2.2066 0.01692 0.00940 Total WHO TEQ 0.00862 0.01465 1.4121 0.01415 0.00880 Notes: Data Qualifiers: NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL). J The analyte was positively identified; the quantitation is an estimation. UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to oilfield screening data.

919689/RVRIRPSite Page I of 6 Table 2-8 Soil Sample Analysis for tbe Site Wide Dioxin Sampling IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S200 HAS39S201 HAS39S202 HAS39S203 HAS39S204 Site 39 Harmon Site 39 Harmon Site 39 Harmon Site 39 Harmon Location Site 39 Harmon Substation Substation Substation Substation Substation Sample Depth bgs (feet) 0.1-0.3 0.1-0.3 0.1-0.3 0.1-0.3 01-03 COC Number 58-033HA 58-033HA 58-033HA 58-033HA 58-033HA Sample Delivery Group Number 46460M 46460 46460 46460 46460 Date Collected 04-Aug-98 04-Aug-98 04-Aug-98 04-Aug-98 04-Aug-98 EPA Analyte Units Concentration Method Dioxins "E/fcg 8290 Total EPA TEQ 0.00930 0.01440 0.01668 0.01060 0.02100 Total WHO TEQ 0.00753 0.01146 0.01377 0.00912 0.01718

Notes: Data Qualifiers: NA Not Applicable I'Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL). J The analyte was positively identified; the quantitation is an estimation. UJ The anafyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to oilfield screening data.

9l968°«>VRiRpSite "->e2of6 Table 2-8 (continued) Soil Sample Analysis for the Site Wide Dioxin Sampling IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S205 HAS39S206 HAS39S207 HAS39S208 HAS39S209 Site 39 Harmon Site 39 Harmon Site 39 Harmon Site 39 Harmon Location Site 39 Harmon Substation Substation Substation Substation Substation Sample Depth bgs (feet) 01-0.3 0.1-0.3 0.1-0.3 0 1-0.3 0.1-03 COC Number 58-033HA 58-033HA 58-033HA 58-033HA 58-033HA Sample Delivery Group Number 46460 46460 46460 46460 46460 Date Collected 04-Aug-98 04-Aug-98 04-Aug-98 04-Aug-98 04-Aug-98 EPA Analyte Units Concentration Method Dioxins Jtg/kg 8290 Total EPA TEQ 0.02100 0.00866 0 00773 0.01910 0.00710 Total WHO TEQ 001790 0.00787 0.00700 0.01636 0.00678 Notes: Data Qualifiers: NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL) J The analyte was positively identified; the quantitation is an estimation. UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to all field screening data.

919689/RVRIRPSitc Page 3 off. Table 2-8 (continued) Soil Sample Analysis for the Site Wide Dioxin Sampling IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S210 HAS39S211 HAS39S212 HAS39S213 HAS39S214 Site 39 Harmon Site 39 Harmon Site 39 Harmon Site 39 Harmon Location Site 39 Harmon Substation Substation Substation Substation Substation Sample Depth bgs (feet) 01-0.3 0.1-0.3 0.1-0.3 0.1-0.3 0.1-0.3 COC Number 58-034HA 58-034HA 58-034HA 58-034HA 58-034HA Sample Delivery Group Number 46460 46460 46460 46460 46460 Date Collected 07-Aug-98 07-Aug-98 07-Aug-98 07-Aug-98 07-Aug-98 EPA Analyte Units Concentration Method Dioxins Pg/kK 8290 Total EPA TEQ 0.00660 0.05550 0.42020 0.12470 001370 Total WHO TEQ 0.00589 0.04501 0.36385 0.11005 001226 Notes: Data Qualifiers: NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not delected. The associated numerical value is at or below the Method Detection Limit (MDL). J The analyte was positively identified, the quantitation is an estimation. UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria. S Applied to oilfield screening data.

91968° ""VR IRP Site Table 2-8 (continued) Soil Sample Analysis for the Site Wide Dioxin Sampling IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S406 HAS39S407 HAS39S408 HAS39S409 Location HAS39S155A HAS39S155A HAS39S155B HAS39S155B Sample Depth bgs (feet) 05 15 0.5 1.5 COC Number 58-062HA 58-062HA 58-062HA 58-062HA Sample Delivery Group Number 47480rl 47480rl 47480H 47480rl Date Collected 07-Dec-98 07-Dec-98 07-Dec-98 07-Dec-98 EPA Analyte Units Concentration Method Dioxins fig/kg 8290 Total WHO TEQ 0.0207 00015 0.0353 0.0622 Notes: Data Qualifiers: NA Not Applicable / Not Analyzed U The analyte was analyzed for, but not detected The associated numerical value is at or below the Method Detection Limit (MDL) J The analyte was positively identified, the quantitation is an estimation UJ The analyte was analyzed for, but not detected The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample B The analyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to oilfield screening data.

919689/RVRIRPStte Page 5 of 6 Table 2-8 (continued) Soil Sample Analysis for the Site Wide Dioxin Sampling IRP Site 39/Harmon Substation, Andersen AFB, Guam Sample ID HAS39S410 HAS39S411 HAS39S412 Duplicate of Location HAS39S155C HAS39S155C HAS39S406 Sample Depth bgs (feet) 0.5 1.5 0.5 COC Number 58-062HA 58-062HA 58-062HA Sample Delivery Group Number 48480rl 47480r2 47480rl Date Collected 07-Dcc-98 07-Dec-98 07-Dec-98 EPA Analyte Units Concentration Method Dioxins MB/kg 8290 Total WHO TEQ 0.0010 .00162* 0.0217 Notes: Data Qualifiers: NA Not Applicable /Not Analyzed U Hie analyie was analyzed for, but not detected. The associated numerical value is at or below the Method Detection Limit (MDL) * preliminary result J The analyte was positively identified; the quantitation is an estimation. UJ The analyte was analyzed for, but not detected. The reported MDL is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. B The anafyte was found in an associated blank. R The data are unusable due to deficiencies in the ability to analyze the sample and meet QC criteria S Applied to oilfield screening data.

9196r "H IRP Site -e6of6 Appendix C

Human Health and Ecological Risk Assessments (IT/OHM, 1999) Final

Confirmation Human Health Risk Assessment For IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

Prepared by:

IT Corporation 312 Directors Drive Knoxville, Tennessee

July 26,1999

Revision 1 Table of Contents.

Page M-

List of Tables in List of Figures iv List of Acronyms v M. 1 Introduction 1 M.2 Data Evaluation 1 M.2.1 Data Sources and History 2 M.2.1.1 Background 2 M.2.1.2 Site Investigation and Remediation History 2 M.2.2 Data Validation 2 M.2.3 Selection of Chemicals of Potential Concern 4 M.2.4 Summary Statistics of Site-Related Data 5 M.2.5 Chemicals of Potential Concern 7 M.3 Exposure Assessment 8 M.3.1 Characterization of Physical Setting & Site Background 8 M.3.2 Conceptual Site Model 9 M.3.3 Source and Exposure Media 10 M.3.4 Release Mechanisms and Transport Pathways 10 M.3.5 Receptor Scenario and Exposure Pathway Assessments 10 M.3.6 Quantification of Exposure-Point Concentrations 13 M.3.6.1 Exposure-Point Concentrations in Soil 13 M.3.6.2 Exposure-Point Concentrations in Ambient Air 13 M.3.7 Quantification of Chemical Intake 14 M.3.7.1 Inhalation of Chemicals in Air 15 M.3.7.2 Incidental Ingestion of Chemicals in Soil 15 M.3.7.3 Dermal Contact with Chemicals in Soil and Dust 16 M.3.8 Justification of Intake Model Variables 16 M.3.8.1 Groundskeeper 17 M.3.8.2 Trespasser 17 M.3.8.3 Resident 18 M.4 Toxicity Assessment 18 M.4.1 Evaluation of Cancer Effects 19 M.4.2 Evaluation of Noncancer Effects 21

P \RISK2\HUMAJAGUAM\GUAM2\SBC1 WPD, 7/27/99(3 21 poo) ' Table of Contents (Continued).

Page M-

M.4.2.1 Noncancer Toxicity Reference Values 21 M.4.2.2 Target Organ Toxicity 22 M.4.3 Dermal Toxicity Values 23 M.4.4 Sources of Toxicity Information Used in the Risk Assessment 23 M.4.4.1 Toxicity Values 23 M.4.4.2 Gastrointestinal Absorption Factors 24 M.5 Risk Characterization 25 M.5.1 Risk Characterization Methodology 25 M.5.1.1 Cancer Effects of Chemicals 25 M.S.1.2 Noncancer Effects of Chemicals 27 M.5.2 Risk Characterization Results 28 M.5.2.1 Cancer Risk 28 M.5.2.2 Noncancer Hazard 28 M.6 Uncertainty Evaluation 28 M.6.1 Uncertainty Terminology 28 M.6.2 Sources of Uncertainty 29 M.6.2.1 Selection and Quantification of COPC 29 M.6.2.2 Estimation of Modeled Exposure Point Concentrations 30 M.6.2.3 Selection of Hypothetical Receptors and Potential Exposure Pathways 30 M.6.2.4 Quantification of Intakes 30 M.6.2.5 Toxicity Assessment 30 M.6.2.6 Risk Characterization 32 M.6.3 Site-Specific Uncertainty 32 M.7 Summary of the Baseline Human Health Risk Assessment 33 M.8 References 34 Appendix M: Attachment 1 -Data Used to Complete Confirmation HHRA Appendix M: Attachment 2 - Toxicological Profiles for Chemicals of Potential Concern

P \WSK2VHUMAN\GUAM\GUAM2\SEC1.VWD. 7/27/99(3.21 pm) List of Tables.

Number Title Follows Page M-

M-l Selection of Chemicals of Potential Concern, Total Soil 4 M-2 Variables Used to Estimate Potential Chemical Intakes and Contact Rates for Receptors 7 M-3 Toxicity Values Applied to Evaluate Chemicals of Potential Concern 8 M-4 Groundskeeper Intake Doses and Risk Hazard Estimates for Exposure to Total Soil 28 M-5 Trespasser Intake Doses and Risk Hazard Estimates for Exposure to Total Soil . . 28 M-6 Residential Intake Doses and Risk Hazard Estimates for Exposure to Total Soil. . 28 M-7 Summary of Risks and Hazards from Total Soil 28

P VRJSK2VHUMAN\GUAMVGUAM2\SEC1.WPD, 7/27/99(3:21 pm) List of Figures.

Number Title Follows Page M-

M-l Conceptual Site Exposure Model 8

P \MSK2VHLttlANVOUAM\GUAM2\SEClWPD. 7/27/99(3 21 pm) IV List of Acronyms.

AAFB Andersen Air Force Base cm2 square centimeters COPC chemical(s) of potential concern CRQL contract-required quantitation limit CSEM conceptual site exposure model EPA U.S. Environmental Protection Agency g/m3 grams per cubic meter GAF gastroinstestinal absorption factor Harmon Substation IRP Site 39/Harmon Substation HEAST Health Effects Assessment Summary Tables HHRA human health risk assessment HI hazard index HQ hazard quotient ILCR incremental lifetime cancer risk IRIS Integrated Risk Information System IRP Installation Restoration Program kg kilogram m3 cubic meter mg/day milligrams per day MDC maximum detected concentrations NCEA National Center for Environmental Assessment PAH polynuclear aromatic hydrocarbon PRG preliminary remediation goal RfC reference concentration RfD reference dose RME reasonable maximum exposure SF slope factor UCL upper confidence limit

P \RISK2\HtJMANVJUAM\GUAM2\SECI.WPD, 7/27/99(3.21 pm) M.1 Introduction This Appendix presents a confirmation human health risk assessment (HHRA) to assess residual risk from Installation Restoration Program (IRP) Site 39/Harmon Substation (Harmon Substa- tion), Andersen Air Force Base (AAFB), Guam. This HHRA was performed to verify the results of the removal actions performed by the United States Air Force under the IRP. These activities are discussed in detail in the body of this report. Determining the presence or absence of residual risk will support risk management decision regarding additional remediation requirements, if any, and land use options for the site. Residual risk to human health from environmental media remaining at Harmon Substation was characterized in accordance with U.S. Environmental Protection Agency (EPA) guidance for performing baseline risk assessments (EPA, 1989a; EPA, 199 la; EPA, 1992a,b,c). The location and layout of Harmon Substation are described in Section 1 of this report and depicted in Figures 1-2 and 2-1, respectively.

The remainder of this Appendix is organized as follows: Section M.2 discusses site history, analytical data validation, selection of chemicals of potential concern (COPC), and estimation of source-term concentrations for each COPC in each medium. Section M.3 describes the processes used to determine exposure scenarios, plausible receptors, exposure pathways, exposure-point concentrations (for COPC), and estimate dose or contact rates for each COPC. Section M.4 provides the toxicity assessment and describes the hazard evaluation (i.e., the adverse health effects associated with each of the COPC) and the dose-response evaluation, (i.e., the relationship between dose or contact rate and the magnitude of the adverse effect). Section M.5 presents the risk characterization that quantifies the risk to each receptor through combining output from the exposure analysis with that from the toxicity analysis. Finally, Section M6 describes the uncer- tainty evaluations, and qualitatively addresses uncertainties associated with assumptions and parameters used in the HHRA.

M.2 Data Evaluation Data were collected from the site and evaluated in accordance with EPA guidelines. This process includes evaluating sample collection and analytical methods, evaluating the quality of the data, and comparing the data to EPA Region IX Preliminary Remediation Goals (PRGs) (1998). The purpose of this selection process is to identify any chemicals that could be harmful to human health if they are present at the site, identify those chemicals that are likely to be site-related, and evaluate the acceptability of the analytical data for use in the quantitative risk assessment (EPA, 1989a).

P.\IUSKZ\HUMAMGUAM\GUAM2\SEC2.VVPD. 07-27-99(2:56 pen) M-1 M.2.7 Data Sources and History

M.2.1.1 Background A large number of samples from Operable Unit 3 investigations were used to develop threshold values for inorganic chemicals at AAFB. Lead was the only inorganic chemical evaluated as a potential COPC at Harmon Substation. Lead concentrations were below the PRG for lead, therefore comparison with background was not required in order to characterize risk from lead at the site.

M.2.1.2 Site Investigation and Remediation History Historical information regarding site usage and environmental investigation and remediation activities is provided in the body of this document. Section 1 provides general background information, and Section 2 provides remediation background information.

M.2.2 Data Validation Data validation is an after-the-fact, independent, systematic process of evaluating data. Data are compared to pre-established criteria to confirm that the data are of acceptable technical quality. Specific criteria are reviewed to determine whether the data meet the established data quality objectives for the project. There are five principal quality objectives:

• Precision • Accuracy • Completeness • Comparability • Representativeness.

To verify that these objectives are met, field measurements, sampling and handling procedures, laboratory analysis and reporting, and nonconformances and discrepancies in the data are examined to determine compliance with appropriate and applicable procedures. The procedures and criteria for validation are defined in the Andersen Air Force Base, Final Basewide Quality Assurance Project Plan (AAFB, 1997), the U.S. EPA SW-846, "Test Methods for Evaluating Solid Waste," Update H (EPA, 1994a), and the U.S. EPA Contract Laboratory Program National Functional Guidelines for Inorganic and Organic Data Review (EPA, 1994b).

.The validation process for data from Harmon Substation was divided into two phases. The first phase considered field data to verify the completeness, accuracy, and representativeness of field

M-2 sampling. The second phase dealt with analytical chemical validation. The important field data reviewed in the validation process are:

• Field logbooks • Specific field forms for sample collection and handling • Analytical Request (AR)/Chain-of-custody (COC) • Field instrument calibrations • Field personnel training • Variances and surveillance of field activities.

The primary analytical data and parameters reviewed in the validation process are:

• Organic constituent analyses: - Holding times and preservation - Gas chromatography or high performance liquid chromatography performance - Initial and continuing instrument calibration - Surrogate recoveries - Internal standards - Method blanks - Laboratory control samples - Matrix spikes and matrix spike duplicates - Compound quantitation and identification - Field duplicate precision

• Inorganic constituent analyses: - Holding times and preservation - Instrument performance checks - Initial and continuing calibrations - Matrix spike and matrix spike duplicate evaluations - ICP serial dilution and interference checks - Laboratory control sample checks - Duplicate sample analysis - Compound quantitation and identification - Field duplicate precision.

The data used to complete confirmation HHRA is presented in Attachment 1 to this Appendix. A subset of the data was validated by a third party (Jacobs Engineering, Inc., California). The remaining sample data were validated by contractor chemists assigned to the project who are experienced in data validation protocols. Detailed data quality assessment reports are available upon request, for all data packages containing data used for risk assessment purposes.

P.\WSK2\HUMAN\GUAMVGUAM2\SEC2 WPD, 07-27-99(2^9 pm) M-3 All environmental sampling data are evaluated for suitability for use in the risk assessment. Analytical results for chemicals are reported using Air Force Center for Environmental Excellence and Contract Laboratory Program data qualifiers. Chemicals flagged with a "U" qualifier are considered to be not detected, or detected at a concentration below the normal, random "noise" of the analytical instrument. Estimated quantitative results such as those identified by a "J" qualifier are used in the assessment. The " J" qualifier describes an estimated value when a compound is present (spectral identification criteria are met), but at values less than the contract-required quantitation limit (CRQL), or when quality control samples suggest that the sample results may be in error (e.g., when spike samples are outside of required limits or when holding times are just outside limits). Data with a "UJ" qualifier are treated as not detected for the purposes of data evaluation and risk assessment. If validation of the data reveals that samples must be rejected (assigned an "R" qualifier), the rejected data are not used for the risk assessment. The data utilized in this risk assessment have been validated, and determined suitable for use in a Human Health Risk Assessment to address potential residual risk from soil at Harmon Substation.

M.2.3 Selection of Chemicals of Potential Concern Chemicals of potential concern are selected following the validation of data, compilation of summary statistics, and comparison with site background and PRGs (EPA 1989a, 1998). The COPC selection criteria for chemicals to be retained as COPC, as recommended by EPA (1989a, 1998), are illustrated in Table M-l, and are as follows:

• Frequency of Detection. Chemicals were eliminated if they were detected infrequently (5 percent or lower frequency of detection), providing there was no evidence that infrequent detection reflected a "hot spot" location.

• Risk-Based Screening. The risk-based screening is applied in a phased manner. First, the maximum detected concentration (MDC) of a chemical is compared with the corresponding EPA (1998) PRG value for residential soil; chemicals are ex- cluded from further consideration if the MDC is less than or equal to the PRG. If the MDC exceeds the PRG, the source-term concentration, based on the best-fit distribution of the data, is then compared with the PRG. A chemical is excluded from further consideration if the source-term concentration is less than or equal to the PRG.

• Background. If the mean chemical concentration of a sample is less than the mean of the background concentration, the chemical is excluded from further consider- ation as a COPC. If the mean of the chemical concentration is marginally greater than the background mean, a statistical analyses may be performed to determine if the sample mean is statistically greater than the background mean.

P \WSK2VHUMA1TOUAM\GUAM2\SEC2 WPD, 07-27-99(2 56 pm) M-4 Table M-1

Selection of Chemicals of Potential Concern, Total Soil * IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

(Page 1 of 2)

Range of values, ug/kg Risk-Based Source-Term Detection Detected Concentrations Detection Limits* Statistical Mean 95% UCL Screening Criterion Concentration Chemical Frequency Minimum Maximum Minimum Maximum Distribution" ug/kg ug/kge ug/kg " COPC?" ug/kg • oxin OXIN (WHO) TEQ 39 /39 0.001 - 1.4121 NA NA NP 6.06E-02 1.38E-02 3.80E-03 Y 1.38E-02 organic* ad /35 5990 - 149000 NA U 32 NA 3.18E + 04 4.00E+05 N(a) — >lynuctaar Aromatic Hydrocarbon* (PAH) ithraoene 8 188 2.74 - 29.4 NA NA U 2.12E+00 1.40E+06 N(a) — nzo(a|anthracen8 27 1 88 2.51 - 71.6 NA - NA U 9.53E+00 5.57E+02 N(a) — >nzo(a)pyran« 29 1 88 6.22 - 87.5 NA - NA L 1.21E+01 1.66E+01 5.60E+01 Y 1.66E+01 nzo(b)fluorenth«ne 35 1 88 6.94 - 126 NA - NA U 1.76E + 01 5.60E-I-02 N(a) —

otal soil equals post-remedial surface, subsurface, and stockpile soil sampled and remaining on-sHe. i_Ai-«t t m»A.lt...*i . * 1 *« - 1 -U-ML^ .•!««> LIB • Mw»H.r«>M.arl* *41»Mti.rfl^ Mtrue ««~«« AA|« ujUU Mrd»*t«r Mt«n CA4t rlntaMa If «4*t4 oatfaiU »nnm\* l anr4 Innnnrmaf* = Distribution not determined If maximum concentration Is less than screwing criteria. 1% Upper confidence limit calculated for chemicals wHh maximum detected concentrations greater than screening criteria. ased on Region 9 preliminary remediation goals (PRG) for residential soil IngesHon, adjusted, If necessary to reflect an incremental lifetime cancer risk of 1E-6 and a hazard idex of 0.1 (EPA, 1998, PRG Table, 1 May, EPA Region 9).

P |RWC?Hn™nCuamV?«v1\nev10rimTlimU3-7j*W-l CWCWZMW (3.01 PMyDO Table M-1

Selection of Chemicals of Potential Concern, Total Soil * IRP Site 39/Harmon Substation Andersen Air Force Base, Guam (Page 2 of 2) ' Rationale far exclusion of chemical as a contaminant of potential concern (COPC): (a)* maximum detection l« teas than screening criteria. ' N * Chemical to not chosen as a COPC; Y * Chemical Is chosen as COPC. ' Concentration used in risk assessment equal to 95% UCL or maximum value, whichever Is less. " Based on PRO for chtordane. 1 Based on PRG for endrin. 1 Derived, see text. " Detection limits were either unreliable or unavailable and are not reported. NA-Not available TEQ * TCDD equivalent concentration for dioxins • Chemical Specificity. Analytical results that were not specific for a particular compound were excluded from further consideration, unless toxicity values were located that sufficiently reflect the toxicity of the chemical (e.g., PCBs for Aroclor 1248, chlordane for alpha-chlordane).

M.2.4 Summary Statistics of Site-Related Data The statistical methods used in data evaluation are discussed in this section, and reflect EPA guidance (EPA, 1989a). Summary statistics for soil samples from Harmon Substation are included in the COPC Table (Table M-l). The following information was tabulated in each:

• Chemical name • Detection frequency • Range of detected concentrations • Range of detection limits • Statistical distribution • Mean concentrations • 95 percent upper confidence limit (UCL) on the mean • Risk-based screening criterion • COPC selection • Source-term concentration.

Because of the uncertainty associated with characterizing contamination in environmental media, the UCL of the mean was estimated for each chemical in each specific media. In general, "outliers" were included in the calculation of the UCL because high values hi site-related data are seldom outliers. Inclusion of outliers increases the overall conservatism of the risk estimate. Chemical data sets containing five or more samples are tested for normality and lognormality using the Shapiro-Wilks test (EPA, 1992d), from the software package STATISTICA™ (StatSoft, Inc., 1995). UCL estimates are performed only for those chemicals whose MDCs exceed their PRG. If statistical tests support the assumption that the data is normally distributed, the UCL for a normal distribution is calculated. If the statistical analysis shows the data to be lognormally distributed, the UCL is calculated for a lognormal distribution. If the data fit both normal and lognormal distributions, the UCL is calculated for the distribution that appears to provide the best fit.

The UCL is calculated for a normal distribution as follows (EPA, 1992a):

UCL = x +',-„,,,. t

P \WSK2\HUMANV3UAMCUAM2\SECIWPD. 07-37-99(2:56 pm> M-5 where:

x = sample arithmetic mean tt = critical value for student's plus distribution a = 0.05 (95 percent confidence limit for a one-tailed test) n = number of samples in the set s = sample standard deviation.

The UCL is calculated for a lognormal distribution as follows (Gilbert, 1987):

UCL = e where:

y = sample arithmetic mean of the log-transformed data, y = In x Sy = sample standard deviation of the log-transformed data n = number of samples in the data set HO9 j = value for computing the one-sided upper 95 percent confidence limit on a lognormal mean from standard statistical tables (Land, 1975).

A nonparametric confidence limit is used when the data fit neither a normal nor a lognormal distribution as identified with a Shapiro-Wilks test. This occurs commonly in environmental chemical concentration data sets when most of the data points are nondetects or very low concentrations, and one or two data points are relatively high, yielding a skewed distribution with a large tail to the right. Although lognormal parameters can be estimated for these data sets, their use in UCL estimation is generally not appropriate, resulting in the estimation of UCLs orders of magnitude above the MDC. Treating these data sets as lognormal effectively ignores the fact that most of the data were nondetects or very low values, and incorrectly imposes the MDC as a reasonably conservative estimate of average. The nonparametric UCL is introduced to address this problem while not failing to capture the size of the upper tail in truly lognormal distributions.

The nonparametric UCL is the UCL on the median, rather than the mean, because the median is a better estimate of central tendency for a nonparametric distribution. It is estimated by ranking the data observations from smallest to largest. The rank order of the observation selected as the UCL is estimated from the following equation (Gilbert, 1987):

P \MSK2\HUMAN\GUAMVGUAM2\SEC2 WPD. 07-27-99(2:56 pm) M-6 w = p(n + 1) + where:

u = rank order for data point selected as the UCL p = quantile on which UCL is being calculated; p = 0.5 n = number of samples in the set a = confidence limit; 95 percent Z,_a = normal deviate variable for one-sided UCL = 1.645.

For data sets of small samples sizes (less than 10), the nonparametric UCL is generally the MDC

Analytical results are presented as nondetects, whenever chemical concentrations in samples do not exceed the detection or quantitation limits for the analytical procedures of those samples. Generally, the detection limit is the lowest concentration of a chemical that can be "seen" above the normal, random "noise" of an analytical instrument or method. To apply the previously men- tioned statistical procedures to a data set containing nondetected values, a concentration must be assigned to the nondetect. In this assessment, a value of one-half the detection limit is assigned to nondetected values (EPA, 1989a).

M.2.5 Chemicals of Potential Concern This risk assessment evaluates risk from chemicals in total soil sampled, analyzed, and remaining at Harmon Substation. Summary statistics and the selection of COPC for chemicals detected in total soil (surface and subsurface) remaining at the site are presented in Table M-2. A total soil approach is applied, because post-sampling backfilling activities at Harmon Substation make it difficult to positively identify the locations of sampled strata. Samples collected from surface soil may now represent subsurface soils; and samples collected from subsurface soil may now represent surface soils. Assessment of risk from chemicals in "total soil" is the only practicable media evaluation option for Harmon Substation, because it is possible that, in the future any given soil unit could end up as either on- or off-site surface or subsurface soil.

It is possible that stockpile or other soil from Harmon Substation will be removed by nearby residents or contractors in the future and applied as fill material at either on- or off-site construc- tion projects. As discussed in Section M.S.5 below, the construction worker receptor scenario is

P \WSK2VHUMAN\GUAM\GUAM2\SEC2 WFD, 07-27-99(2-56 pm) M-7 Table M-2

Variables Used to Estimate Potential Chemical Intakes and Contact Rates for Receptors IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

(Page 1 of 2)

Pathway Variable Groundskeeper Trespasser Resident11 General Parameters Used in All Intake Models Exposure Duration (years) 25* 10b NA Adult NA NA 24 Child NA NA 6 Exposure Frequency (days/year) 250* 52b 350 Body Weight (kg) 70" 45b NA Adult NA NA 70 Child NA NA 15 Averaging Time-Noncancer (days) 9125 d 3650" 2190 Averaging Time-Cancer (days) 25550 • 25550 • 25550 Inhalation of Resuspended Dust from Soil Inhalation Rate (m3/hour) Adult 2.5* 1.9" NA Inhalation Rate-Air (m3/day) Adult NA NA 20 Child NA NA 10 3 Inhalation Factorsdl (m -yr/kg-day) NA NA 10.9 Exposure Time (hours/dayj_ 8* 6b NA Incidental Ingestion of Soil Ingestion Rate-Soil (mg/day) 100* 100* NA Ingestion Rate-Soil (mg/day) Adult NA NA 100 Child NA NA 200 Ingestion Factor,,,, (mg-yr/kg-day) NA NA 114 Dermal Contact with Soil Skin Adherence-Soil (cm2) 5000" 3700" NA Skin Adherence-Soil (cm2) Adult NA NA 5000 Child NA NA 2000 SFS^, (mg-yr/kg-day) NA NA 344 Adherence Factor (mg/cm2) 0.2° 0.2s 0.2"

Absorportion Factor (unitless) CSV CSV CSV Table M-2 ^'V'" f S"*! *> Variables Used to Estimate Potential Chemical Intakes and Contact Rates for Receptors IRP Site 39/Harmon Substation Andersen Air Force Base, Guam (Page 2 of 2)

' EPA, 1991, Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual Supplemental Guidance, Standard Default Exposure Factors, Interim Final. b Assumed; see text. c Refer to Section 6.3.8. "Calculated as the product of ED (years) x 365 days/year. •Calculated as the product of 70 years [assumed human lifetime (EPA, 1989, Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual (Part A)] x 365 days/year. 'Calculated, see text 8 EPA, 1992, Dermal Exposure Assessment Principles and Applications, EPA/600/8-91/011B "EPA, 1996, Region IX Preliminary Remediation Goals (PRGs), EPA Region IX, San Francisco, California, August.

NA = Not Applicable. csv = Chemical-specific value.

P \RISK2\ffiJMAN\GUAM\GUAM2\XBLM-2 WPD/07-27-»(3:2p) not evaluated, because a more conservative estimate of risk from soil ingestion is included in the evaluation of risk to the groundskeeper.

Based on the PRG-based selection procedures and criteria previously described, the COPC for total soil at Harmon Substation, as selected in Table M-l, are:

• Total WHO Dioxin (2,3,7,8-tetrachlorodibenzo-p-dioxin, samples were analyzed for total rather than individual dioxins)

• PAH (Benzo(a)pyrene)

• PCB (Aroclor 1254).

M.3 Exposure Assessment Exposure is the contact of a receptor with a chemical or physical agent. An exposure assessment estimates the type and magnitude of potential exposure of a receptor to a COPC found at or migrating from a site (EPA, 1989a). The exposure assessment included the following steps:

1) Characterization of the physical setting 2) Identification of chemical sources, release mechanisms, and migration pathways 3) Identification of potentially exposed populations or receptors 4) Identification of potential exposure pathways 5) Estimation of exposure concentrations 6) Estimation of chemical intake or contact rates.

The exposure assessment includes the development of the conceptual site exposure model (CSEM) (Figure M-l) and the development of inputs used in the risk assessment. The latter are presented in Table M-2, Variables Used to Estimate Potential Chemical Intakes, and Table M-3, \ Toxicity Values Applied to Evaluate Chemicals of Potential Concern.

M.3.7 Characterization of Physical Setting & Site Background Section 1 of this report describes the physical characteristics of this site, including communities that may be in the area that may be affected by chemicals at the site.

Harmon Substation is located in the Harmon Annexes of AAFB, Guam. The site, which is heavily overgrown with swordgrass, is approximately nine acres in size. The surrounding land is either industrial (Harmon Substation) or undeveloped/vegetated. There are no residential or recre- ational areas adjacent to the site. The nearest surface water body is the Philippine Sea, which is

P \RJSK2\HUMAN\GUAlvK3UAM2VSEC2 WFD, 07-27-99(256 pm) M-8 Figure M-1

Conceptual Site Exposure Model IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

SOURCE MEDIUM RELEASE/TRANSPORT EXPOSURE MEDIUM EXPOSURE ROUTE HYPOTHETICAL RECEPTORS MECHANISM (Curren t an d Future ) 1 Constructio n Worke r 1 (Future ) 1 (Future ) \ Trespasse r j Groundskeepe r 1 (Future ) I Residen t 1 Sportsma n 1 (Curren t an d Future ) 1 a^ *- Wild w Plant Uptake \ 2 1 1 1 i L ^ Game Direct Ingestion

TOTAL SOIL Incidental Ingestion 2 • • 2 aw • (Surface and ~W Soil Subsurface) Dermal Contact • 2 • • 2

Dust Emissions |t Air Volatilization Dust Inhalation • 2 • • 2

• » Evaluated - complete exposure pathway. 1 = Incomplete exposure pathway. 2 = Not evaluated - complete exposure pathway (see text Section M.3.5 for explanation).

P \Rislc2\Humin\Guun\Omm2VFigM-1 .ppf. 7/27/99 3.05 PM Table M-3

Toxicity Values Applied to Evaluate Chemicals of Potential Concern IRP Site 39/Harmon Substation Andersen Air Force Base, Guam Oral Oral Inhalation Inhalation Dermal Dermal Chemical of Gastrointestinal Soil Slope Reference Slope Reference Slope Reference Potential Absorption Absorption Factor Dose Factor Dose Factor Dose Concern Factor Factor (kg-day/mg) (mg/kg-day) (kg-day/mg) (mg/kg-day) (kg-day/mg) (mg/kg-day) ioxin 'ioxin (2,3,7,8-TCDD) 0.9 1.00E-02 1.50E+05 ND 1.10E+05 ND 1.67E+05 ND AH enzo(a)pyrene 0.5 1.00E-02 7.30E+00 ND 3.10E+00 ND 1.46E+01 ND CB roclor 1254 0.9 6.00E-02 2.00E+00 2.00E-05 2.00E+00 ND 2.22E+00 1.80E-05

D « No data ,3,7,8-TCDD = 2,3,7,8-tetrachlorodibenzo-p-dioxin AH = Polynuclear aromatic hydrocarbon CB = Polychiorinated biphenyl oxicological references used to derive the data In this table are listed in Appendix M, Attachment 1, Toxicological Profiles for Chemicals of Potential Concern.

tnAlt IMP located approximately one mile west of the site. In Chapter 1.0, see Figure 1-1 "Location Map Harmon Annexes, Andersen AFB, Guam" and Figure 1-2, "Location Map IRP Site 39/Harmon Substation, Harmon Annexes, Andersen AFB, Guam," for the precise location of this site.

Harmon Substation is a former waste disposal site. There is little recorded information available regarding waste disposal practices and previous historic land use at the site. Most available information originated in a report addressing buried drums found at the site in 1989, during excavation activities related to the petroleum, oil, lubricants pipeline which borders the northern edge of the site. Additional investigation and remediation-related information is provided in Section 2, supra.

Removal actions were conducted at Harmon Substation beginning in April of 1998. The objectives of the remedial actions were to:

• Clean, remove, demolish, and remediate the "oil/water separator system"

• Remediate the "buried drum area"

• Remediate the polynuclear aromatic hydrocarbon (PAH) "hot spots"

• Remediate the "miscellaneous container area"

• Perform confirmation sampling and analysis following all remedial activities

• Evaluate dioxin contamination

• Ensure safe and compliant off-site transportation and disposal of all wastes, contam- inated soil and related debris

• Backfill the excavations

» Prepare a remedial verification report.

The removal actions have been completed. A complete account of operational and remediation activities at Harmon Substation is presented in Chapters 2 and 3 of this document.

M.3.2 Conceptual Site Exposure Model The CSEM provides the basis for identifying and evaluating potential risks to human health in the HHRA. The CSEM (Figure M-l) includes both current and future land-use scenarios for Harmon

f \RlSia\HUMAWGUAlvW3UAM2\SECZWPD. 07-27-99<2:S6 pm) M-9 Substation, receptors appropriate to all plausible scenarios, source media, chemical release and transport mechanisms, exposure media, and potential exposure pathways. By graphically presenting all plausible pathways and exposure routes, the conceptual site model facilitates the consistent and comprehensive evaluation of risk to human health, and helps ensure that potential pathways are not overlooked. The elements necessary to construct a complete exposure pathway and develop the CSEM include:

• Source (i.e., chemicals in environmental media) • Chemical release mechanisms • Chemical transport pathways • Receptors • Exposure pathways.

Chemical release mechanisms and transport pathways are not required for direct receptor contact with a source medium.

M.3.3 Source and Exposure Media Source and exposure media at Harmon Substation include soil and air (Figure M-l). Soil may be further divided into subsurface and surface soil, although "total soil" is evaluated in this HHRA, for the reasons presented in Section M.2.5. Surface and groundwater and sediment were eliminated as media of potential concern within the baseline characterization and remediation activities for this site (Chapter 3).

M.3.4 Release Mechanisms and Transport Pathways Potential chemical release mechanisms and transport pathways considered hi this assessment include soil dust emissions and volatilization into air (Figure M-l). Again, water-related pathways were eliminated in Chapter 3, Supra.

M.3.5 Receptor Scenario and Exposure Pathway Assessments The objective of these assessments is to identify potential human receptors that may be exposed to site-related chemicals at Harmon Substation. This is applied to both current and future land-use scenarios. At Harmon Substation, plausible current receptors include the sportsman, trespasser and the remediation worker. In this HHRA current risk is only characterized for the trespasser. Current (as well as future risk to) the remediation worker is excluded from this risk assessment, because it is assumed that the remediation worker is cognizant of, and appropriately protected from, all chemical and physical hazards at the Site, in accordance with applicable Occupational

F \RISK2\KUMAKVGUAM\GUAM2\SEC2VVFD. 07-27-99(2.56 pm) M-10 Safety and Health Administration requirements. Therefore, neither current nor potential future risks to the remediation worker are characterized herein.

The sportsman receptor scenario is not characterized for reasons discussed below.

The risk assessment identifies potential future contaminant sources, as well as release mechanisms and pathways, through which receptors may be exposed to site-related chemicals.

The future land use projected for Harmon Substation is industrial, although the site could also be used for residential purposes some time in the future. There are several plausible receptors, who may be exposed under future land-use scenarios for Harmon Substation. The following receptor scenarios are evaluated in this assessment because they provide information that is useful for making decisions regarding additional remediation requirements and land use options for the Site:

• Groundskeeper • Trespasser • Resident.

As shown in the CSEM (Figure M-l), each of the receptors evaluated could potentially be exposed to soil via the following exposure routes:

• Incidental ingestion of soil • Dermal contact with soil • Inhalation of chemicals that are released from soil as dust.

Groundskeeper (Occupational Receptor): The site is currently used for military/industrial purposes. This land use scenario is likely to continue into the future. The groundskeeper receptor scenario is an occupational worker scenario that generally captures the upper risk for incidental ingestion, inhalation and dermal exposure to surface or total soil. The scenario consists of daily maintenance activities that expose the groundskeeper to chemicals in soil for many years. Currently, workers, including groundskeepers are not present at this site. Thus, the grounds- keeper scenario is only evaluated for future land use purposes.

Trespasser: Quantification of risk for the trespasser includes the possibility of current as well as future land-use conditions. The (7 to 16-year-old) trespasser scenario is presented as the only plausible current (along with future) receptor scenario for Harmon Substation. This scenario captures potential risk from Harmon Substation during the time period from the completion of

P:TOSK2\HUMANVGUAMVCHJAM2\SBC2.WPD. 07-27-59(2:56 pm) M-ll recent remediation actions until some unspecified time in the future, when the site is transitioned to an alternative land use.

Resident: The residential risk scenario is evaluated for a hypothetical on-site resident exposed to total soil at Harmon Substation. Even though a residential scenario at this site is unlikely, this residential risk scenario is evaluated in order to provide risk managers an estimate of site risks and hazards based on EPA (1998) Region IX default parameters and assumptions used to derive the PRGs. The residential scenario combines the child and adult receptor scenarios in accordance with Region IX EPA (1998) policy. This scenario often provides the upper boundary for both cancer and noncancer risk from a site. Generally, the adult resident scenario provides the higher cancer risk estimate. Potential risk to an off-site resident from soil removed from the site and used off-site is also covered by this receptor scenario.

Construction Worker: The construction worker scenario is generally the most conservative measure of risk from exposure to subsurface soil. The construction worker scenario is not evaluated, because total, rather than surface and subsurface soil, is evaluated in this HHRA. Where total soil is evaluated, the groundskeeper scenario provides a more conservative risk characterization, and evaluation of the construction worker scenario provides no additional benefit.

Sportsman: This scenario consists of the hunter who enters the site while hunting wild pig or other game. The sportsman is not evaluated as a plausible current scenario, because it is believed that the sportsman does not hunt at this site, and neither pig nor deer have been spotted. Furthermore, it is highly probable that even if the sportsman was hunting at this site, the impacts from Harmon Substation alone would be negligible, given the small size of the site relative to the large foraging and grazing ranges generally associated with wild pig and deer.

The sportsman receptor scenario is not characterized as a future receptor scenario, because the resident receptor scenario provides a much more conservative measure of risk from soil inhalation and dermal exposure pathways. Generally, the sportsman is only included (in addition to the residential receptor) if there is a significant chance of capturing additional risk from direct ingestion of wild game.

A careful analysis of the risk from hunting and consumption of wild deer and pigs across AAFB was conducted in the HHRA for IRP-16 (ICF Kaiser, Inc., 1999). That risk assessment used

P.VRJSK2\HUMAN\GUAM\GUAkO\SEC2.WPD. 07-27-99(2:56 jan) M-l 2 actual animal sample tissue studies to determine that "the [cancer] risk estimated for ingestion of deer and wild pig meat were zero, because the carcinogenic COPCs selected at Site 16 were non- detect in all of the deer and pig tissue samples. Therefore there are no concerns for cancer risk resulting from these (sportsman and residential) exposure scenarios". The HHRA for IRP 16 further indicates that it is appropriate to extrapolate this conclusion to other IRP Sites at AAFB. The IRP 16 HHRA further states that, "Generally, home ranges for deer and wild pig cover areas 50 to 100 times the size of an IRP site. Therefore, these data are appropriate for use in assessing environmental impacts at Site 16, and for hunters across the base" (ICF Kaiser, Inc., 1999).

M.3.6 Quantification of Exposure-Point Concentrations

M.3.6.1 Exposure-Point Concentrations in Soil The source-term concentrations estimated for the COPC in total soil are selected as the exposure- point concentration for the direct contact pathways (ingestion and dermal contact), and as the source-term concentration from which chemical concentrations in air are estimated for the indirect pathway (inhalation). Table M-l presents the source-term concentrations for the chemicals evaluated for COPC selection. Adopting the source-term concentration as the exposure-point concentration is consistent with EPA (1992a) guidance, which specifies that the mean is the appropriate exposure-point concentration to use to estimate risk from chronic exposure. The source-term is generally the UCL on the mean (or the MDC, whichever is smaller) on an unweighted data set, rather than the mean itself. This compensates for uncertainty about the true mean caused by sample limitations. Application of the unweighted UCL is generally a good screening approach when limited site data are available. However use of a more rigorous goestatistical estimation process will provide significant reduction in the overall uncertainty of the risk assessment, when estimating a representative site-mean where significant site data are available.

M.3.6.2 Exposure-Point Concentrations in Ambient Air COPC concentrations in ambient air potentially arise from volatilization of volatile organic compounds and COPC-bearing dust from soil resulting from activity on the site. COPC concen- trations in ambient air inside a building can arise from resuspension of COPC-bearing removable surface dust. The model used to estimate exposure-point concentrations for indirect exposure via ambient air is presented in the following paragraphs.

P \RISK2\HUMAN\GUAM\GUAM2\SECZWPD. 07-27-99(2:56 pm) M-l 3 Dust Emissions. Inhalation exposure to paniculate emissions from soils arises from construction or other site activities that raise dust. Therefore, the most appropriate approach for estimating chemical concentrations in ambient air is the use of an activity-based dust loading equation (DOE, 1989):

C.-CDXC.XCF,) where:

C, = chemical concentration in air (mg/m3 of air) D = dust loading factor (g of soil/m3 of air) C, = chemical concentration in soil (mg/kg) = conversion factor (10"3 kg/g).

Plausible values for D include 6x10"* grams per cubic meter (g/m3) for construction work (DOE, 1983), and 1 x 10"4 g/m3 for all other occupational work (NCRP, 1984).

Volatilization From Soil. The volatilization model applies only to compounds with Henry's law constant greater than 10'$ atm-mVmol and molecular weights less than 200 g/mol (EPA, 199 la). Chemical-specific toxicity parameters for COPC are listed in Table M-3. The organic COPC in Table M-3 are not treated as volatile because their molecular weights are greater than 200 g/mol; thus, the volatilization model was not applied in this assessment and the requisite volatilization model is not reported.

Exposure point concentrations in soil, dust, and ambient air for all the receptors and pathways that were quantified, are listed in the far right column of Table M-l .

M.3. 7 Quantification of Chemical Intake This section describes the models used to quantify dose and intake rates for COPC relative to the exposure pathways previously identified. Table M-2 presents the dose and intake values applied in this HHRA and relevant source references. The intake model variables generally reflect 50th or 95th percentile values, which, when applied to the exposure-point concentrations derived (as described in Section M.3. 6) ensure that the estimated intakes represent the reasonable maximum exposure (RME). The RME scenario also accounts for exposures to sensitive subpopulations such as infants, children, elderly persons, and pregnant and nursing women. Models were taken or modified from EPA (1989a and 1998) unless otherwise indicated. The intake equations for the

P:\IUSK2\HUMAN\GUAMVOUAM2^EC2.WPD, 07-27-99(2:56 pm) M- 1 4 residential receptor are distinguished from the other receptors because these equations have age- adjusted parameters to include both adult and child residents based on EPA (199la) guidance and the precedent set by EPA (1996a). Chemical intakes calculated with the models described below are presented in the receptor-specific risk characterization tables (Tables M-4 through M-6).

M.3.7.1 Inhalation of Chemicals in Air The following equation is used to estimate the inhaled dose of COPC in air for all except the residential receptors (EPA, 1989a):

(BW)(AT) where:

I. - inhaled dose of COPC (mg/kg-day) C, = concentration of COPC in air (mg/m3) IR, = inhalation rate (mVhour) ET = exposure time (hours/day) EF = exposure frequency (days/year) ED = exposure duration (years) BW = body weight (kg) AT = averaging time (days).

M.3.7.2 Incidental Ingestion of Chemicals in Soil The ingested dose of COPC in soil is estimated for all except the residential receptors from the equation (EPA, 1989a):

(BW)(AT) where:

I, = ingested dose of COPC in soil (mg/kg-day) C, = concentration of COPC in soil (mg/kg) IR, = ingestion rate of soil (mg/day) EF = exposure frequency (days/year) ED = exposure duration (years) 6 CF4 = conversion factor (10" kg/rag) BW = body weight (kg) AT = averaging time (days).

P.VRISK2\HUMAN«5UAM«3UAM2\SEC2.WPD. 07-27-99(2:56 pm) M-l 5 M.3. 7.3 Dermal Contact with Chemicals in Soil and Dust Unlike the methodologies for estimating inhaled or ingested dose of COPC, which quantify the dose presented to the barrier membrane (the pulmonary or gastrointestinal mucosa, respectively), dermal dose is estimated as the dose crossing the skin that is systemically absorbed. For this reason, dermal toxicity values are also based on absorbed dose. The absorbed dose of COPC for all except the residential receptors is estimated from the equation (EPA, 1992b).

DAD- (BW)(AT) where:

DAD = average dermal absorbed dose of COPC (mg/kg-day) C. = concentration of COPC in soil (mg/kg) AF = soil-to-skin adherence factor (mg/cm2-event) ABS = absorption fraction (unitiess, chemical-specific value). SA, = surface area of the skin available for contact with soil (cm2) EF = exposure frequency (days/year) ED = exposure duration (years) 6 CF4 = conversion factor (10" kg/mg) CF5 = conversion factor (1 event/day) BW = body weight (kg) AT = averaging time (days).

The dimensional integrity of this equation is maintained through assuming that one exposure event occurs in each exposure day.

M.3.8 Justification of Intake Model Variables In keeping with EPA (1991b) guidance, variables chosen for the RME receptor for ingestion rate, exposure frequency, and exposure duration are generally upperbounds. Other variables, e.g., body weight and surface area are generally central or average values. In the case of contact rates consisting of multiple components, e.g., dermal contact with soil, consisting of absorption factor, and adherence factor, the conservatism built into the individual variables assures that the entire estimate for contact rate is more than sufficiently conservative.

The averaging time for noncancer evaluation is computed as the product of exposure duration (years) times 365 days per year, to estimate an average daily dose over the entire exposure period. For cancer evaluation, averaging time is computed as the product of 70 years, the assumed human

3? \RISK2\HUMAK\GUAM«3UAlv£^SEC2.WPD, 07-27-99(2 56 pm) M- 1 6 lifetime, times 365 days per year, to estimate an average daily dose prorated over a lifetime, regardless of the frequency or duration of exposure. This methodology assumes that the risk from short-term exposure to a high dose of a given carcinogen is equivalent to long-term exposure to a correspondingly lower dose, provided that the total lifetime doses are equivalent. This approach is consistent with current EPA (1986) policy of carcinogen evaluation, although it introduces considerable uncertainty into the cancer risk assessment.

Justification for each of the variables used in the intake equations described in the previous section is presented in the following sections. The intake variable values applied in this risk assessment are summarized in Table M-2.

M.3.8.1 Groundskeeper The groundskeeper is assumed to be a 70 kilogram (kg) adult, who uses the site 8 hours per day, approximately 5 days per week, for a total of 250 days per year, for 25 years (EPA, 1991b). The respiratory rate for the groundskeeper is assumed to be 20 cubic meters (m3) per 8-hour workday (2.5 mVhour), and the soil incidental ingestion rate is assumed to be 100 milligrams per day (mg/day), comparable to that of an agricultural worker.

Clothing provides partial protection against dermal contact with soil, restricting potential contact to approximately 25 percent of the body, or approximately 3,200 square centimeters (cm2) (EPA, 1992b). EPA (1992b) recommends a default value of 0.2 mg/cm2, the lower end of the range of 0.2 to 1.0 mg/cm2, as an average coefficient for soil-to-skin adherence.

M.3.8.2 Trespasser The trespasser is assumed to be a nearby child resident who makes sporadic visits to Harmon Substation. Based on the demographics of the area and the distances from centers of popula- tion to the site, it is assumed that the trespasser makes one successful entry per week (52 days per year), and spends 6 hours per day in the restricted area. The 6 hours per day is assumed to be spent in contact with surface soil.

EPA (1995) defines the trespasser as a 7 to 16-year-old youth with an average BW of 45 kg exposed for 12 years. A respiratory rate of 31.6 L/minute, equivalent to an inhalation rate of 1.9 m3/hour, is estimated for the 45-kg youth engaged in moderate activity (EPA, 1990). An ingestion rate of 100 mg/day is assumed for persons over 6 years old to account for incidental soil and dust ingestion by a resident (EPA, 1991b). EPA (1989a) permits the development of

P \R1SK2'«UMAN\GUA1«J\GUAM2\SEC2 WPD. 07-27-99(2-56 pm) M-17 a fraction term to reflect the proportion of his total daily exposure to soil that a receptor obtains from the contaminated media. It is assumed that the 6 hours per day that the trespasser spends in contact with surface soil, on sites where surface water is not present, represents 38 percent of his daily exposure to soil (potential exposure to soil throughout his waking hours, assumed to be 16 hours per day).

The surface area of the child for dermal contact is estimated to be 3,700 cm2 (EPA, 1996a). The soil adherence factor is assumed to be 0.2 mg/cm2 (EPA, 1992b).

M.3.8.3 Resident The resident receptor scenario is applied to account for both the on- and off-site resident who could be exposed to soil at or from Harmon Substation, respectively. In keeping with EPA Region TX guidance, the residential receptor is a 30-year residential exposure divided into two parts (EPA, 1998). First, a 6-year exposure is calculated for a child, which accounts for a lower body weight (15 kg) and inhalation rate (10 m3/day), and the highest soil ingestion rate of 200 mg/day (EPA, 1998). Second, a 24-year exposure duration is assessed for older children and adults by using an adult body weight (70 kg) and inhalation rate (20 mVday), and a lower soil ingestion rate of 100 mg/day (EPA, 1998).

The surface area of the adult for dermal contact is estimated to be 5,000 cm2 (EPA, 1998). The surface area available for dermal contact for the residential child is estimated to be 2,000 cm2 (EPA, 1998). The soil adherence factor is assumed to be 0.2 mg/cm2 (EPA, 1992b).

M.4 Toxicity Assessment Toxicity is denned as the ability of a chemical to induce adverse effects in biological systems. The purpose of the toxicity assessment is two-fold:

• Identify the cancer and noncancer effects that may arise from exposure of humans to the COPC (hazard assessment); and

• Provide an estimate of the quantitative relationship between the magnitude and duration of exposure and the probability or severity of adverse effects (dose- response assessment).

The latter is accomplished by the derivation of cancer and noncancer toxicity values, as described in the following sections and discussed in detail in Attachment 2 to this Appendix.

P:\RISK2\HUMAN\GUAM\GUAM2\SBC2.WPD. 07-27-99(2:56 pm) M-l 8 M.4.1 Evaluation of Cancer Effects A few chemicals are known, and many more are suspected, to be human carcinogens. The evaluation of the potential carcinogenicity of a chemical includes both a qualitative and a quantitative aspect (EPA, 1986). The qualitative aspect is a weight-of-evidence evaluation of the likelihood that a chemical might induce cancer in humans. The EPA (1986) recognizes six weight-of-evidence group classifications for carcinogenicity:

• Group A - Human Carcinogen: Human data are sufficient to identify the chemical as a human carcinogen.

• Group B1 - Probable Human Carcinogen: Human data indicate that a causal association is credible, but alternative explanations cannot be dismissed.

• Group B2 - Probable Human Carcinogen: Human data are insufficient to support a causal association, but testing data in animals support a causal association.

• Group C - Possible Human Carcinogen: Human data are inadequate or lacking, but animal data suggest a causal association, although the studies have deficiencies that limit interpretation. • Group D - Not Classifiable as to Human Carcinogenicity: Human and animal data are lacking or inadequate.

• Group E - Evidence of Noncarcinogenicity to Humans: Human data are negative or lacking, and adequate animal data indicate no association with cancer.

The toxicity value for carcinogenicity, called a cancer slope factor (SF), is an estimate of potency. Potency estimates are developed only for chemicals in Groups A, Bl, B2 and C, and only if the data are sufficient. The potency estimates are statistically derived from the dose-response curve from the best human or animal study or studies of the chemical. Although human data are often considered to be more reliable than animal data because there is no need to extrapolate the results obtained in one species to another, most human studies have one or more of the following limitations:

• The duration of exposure is usually considerably less than lifetime.

• The concentration or dose of chemical to which the humans were exposed can be only crudely approximated, usually from historical data.

• Concurrent exposure to other chemicals frequently confounds interpretation.

P\RJSK2>HUMAN\GUAWVGUAM2\SECZWPD, 07-27-99(2:56 pm) M-l 9 • Data regarding other factors (tobacco, alcohol, illicit or medicinal drug use, nutritional factors and dietary habits, heredity) are usually insufficient to eliminate confounding or quantify its effect on the results.

• Most epidemiologic studies are occupational investigations of workers, which may not accurately reflect the range of sensitivities of the general population.

• Most epidemiologic studies lack the statistical power (i.e., sample size) to detect a low, but chemical-related increased incidence of tumors.

Most potency estimates are derived from animal data, which present different limitations:

• It is necessary to extrapolate from results in animals to predict results in humans; this is usually done by estimating an equivalent human dose from the animal dose.

• The range of sensitivities arising from genotypic and phenotypic diversity in the human population is not reflected in the animal models ordinarily used in cancer studies.

• Usually very high doses of chemical are used, which may alter normal biology, creating a physiologically artificial state and introducing substantial uncertainty regarding the extrapolation to the low-dose range expected with environmental exposure.

• Individual studies vary in quality (e.g., duration of exposure, group size, scope of evaluation, adequacy of control groups, appropriateness of dose range, absence of concurrent disease, sufficient long-term survival to detect tumors with long in- duction or latency periods).

The SF is usually expressed as "extra risk" per unit dose, that is, the additional risk above background in a population corrected for background incidence. It is calculated by the ex- pression:

where:

p(d) = the probability of cancer associated with dose = 1 mg/kg-day p(0) = the background probability of developing cancer at dose =0 mg/kg-day.

The SF is expressed as risk per mg/kg-day. To be appropriately conservative, the SF is usually the 95 percent upper bound on the slope of the dose-response curve extrapolated from high

•P \RISK2\HUMANV3UAM«UAM2\SEC2.WED, 07-27-99(2:56 pm) M-20 (experimental) doses to the low-dose range expected in environmental exposure scenarios. The EPA (1986) assumes that there are no thresholds for carcinogenic expression; therefore, any exposure represents some quantifiable risk.

The oral SF is usually derived directly from the experimental dose data, because oral dose is usually expressed as mg/kg-day. When the test chemical was administered in the diet or drinking water, oral dose first must be estimated from data for the concentration of the test chemical in the food or water, food or water intake data, and body weight data.

The EPA (1999) Integrated Risk Information System (IRIS) expresses inhalation cancer potency as a unit risk based on concentration, or risk per ug of chemical/m3 of ambient air. Because cancer risk characterization requires a potency expressed as risk per mg/kg-day, the unit risk must be converted to the mathematical equivalent of an inhalation cancer SF, or risk per unit dose. Because the inhalation unit risk is based on continuous lifetime exposure of an adult human (assumed to inhale 20 rn3 of air/day and to weigh 70 kg), the mathematical conversion consists of multiplying the unit risk (per ug/m3) by 70 kg and by 1,000 ug/mg, and dividing the result by 20 mVday. Relevant toxicity input values applied in this HHRA are presented in Table M-3.

M.4.2 Evaluation of Noncancer Effects

M.4.2.1 Noncancer Toxicity Reference Values Many chemicals, whether or not associated with carcinogenicity, are associated with noncancer effects. The evaluation of noncancer effects (EPA, 1989b) involves:

• Qualitative identification of the adverse effect(s) associated with the chemical; these may differ depending on the duration (acute or chronic) or route (oral or inhalation) of exposure

• Identification of the critical effect for each duration of exposure (i.e., the first adverse effect that occurs as dose is increased)

• Estimation of the threshold dose for the critical effect for each duration of exposure

• Development of an uncertainty factor, i.e., quantification of the uncertainty assoc- iated with interspecies extrapolation, intraspecies variation in sensitivity, severity of the critical effect and slope of the dose-response curve, and deficiencies in the database, in regard to developing a reference dose (RfD) for human exposure

P-\RISK2\HUMAN«5UAM«3UAM2\SEC2 WPD. 07-27-99(2:56 pro) M-21 • Identification of the target organ for the critical effect for each route of exposure.

These information points are used to derive an exposure route- and duration-specific toxicity value called an RfD, expressed as mg/kg-day, which is considered to be the dose for humans, with uncertainty of an order of magnitude or greater, at which adverse effects are not expected to occur. Mathematically, it is estimated as the ratio of the threshold dose to the uncertainty factor. For risk assessment purposes, chronic exposure is defined as equal to or greater than seven years, i.e., at least 10 percent of expected lifespan; subchronic exposure is defined as 2 weeks to 7 years. The child exposure scenario, however, is considered chronic, because the exposure duration (6 years) exceeds 10 percent of the time that an individual spends as a child.

IRIS (EPA, 1999) and the Health Effects Assessment Summary Tables (HEAST) (EPA, 1997) express the inhalation noncancer reference value as a reference concentration (RfC) in units of mg/m3. Because noncancer risk characterization requires a reference value expressed as mg/kg- day, the RfC must be converted to an inhalation RfD. Because the inhalation RfC is based on continuous exposure of an adult human (assumed to inhale 20 m3 of air per day and to weigh 70 kg), the mathematical conversion consists of multiplying the RfC (mg/m3) by 20 m3/day and dividing the result by 70 kg.

MA.2.2 Target Organ Toxicity As a matter of science policy, EPA (1989a) assumes dose- and effect-additivity for noncancer effects. This assumption provides the justification for adding the hazard quotients (HQ) or hazard indices (HI) in the risk characterization for noncancer effects resulting from exposure to multiple chemicals, pathways, or media. EPA (1989a), however, acknowledges that adding all HQ or HI values may overestimate risk, because the assumption of additivity is probably appropriate only for those chemicals that exert their toxicity by the same mechanism.

Mechanism of toxicity data sufficient for predicting additivity with a high level of confidence are available for very few chemicals. In the absence of such data, EPA (1989a) assumes that chemicals that act on the same target organ may do so by the same mechanism of toxicity, i.e., target organ serves as a surrogate for mechanism of toxicity. When total HI for all media for a receptor exceeds 1 due to the contributions of several chemicals, it is appropriate to segregate the chemicals by route of exposure and mechanism of toxicity (i.e., target organ) and estimate separate HI values for each.

P \RISK2VHUMANVGUAM\OUAM2^EC1WPD. 07-27-99(2.56 pm) M-22 As a practical matter, since human environmental exposures are likely to involve near- or subthreshold doses, the target organ chosen for a given chemical is the one associated with the critical effect. If more than one organ is affected at the threshold, the more severely affected is chosen. Target organ is also selected on the basis of duration of exposure (i.e., the target organ for chronic or subchronic exposure to low or moderate doses is selected rather than the target organ for acute exposure to high doses) and route of exposure. Because dermal RfD values are derived from oral RfD values, the oral target organ is adopted as the dermal target organ. For some chemicals, no target organ is identified. This may arise when no adverse effects are observed or when adverse effects such as reduced longevity or growth rate are not accompanied by recognized organ- or system-specific functional or morphologic alteration.

M.4.3 Dermal Toxicity Values Dermal RfD values and SFs are derived from the corresponding oral values, provided there is no evidence to suggest that dermal exposure induces exposure route-specific effects that are not appropriately modeled by oral exposure data. In the derivation of a dermal RfD, the oral RfD is multiplied by the gastrointestinal absorption factor (GAF), expressed as a decimal fraction. The resulting dermal RfD, therefore, is based on absorbed dose. The RfD based on absorbed dose is the appropriate value with which to compare a dermal dose, because dermal doses are expressed as absorbed rather than exposure doses. The dermal SF is derived by dividing the oral SF by the GAF. The oral SF is divided, rather than multiplied, by the GAF because SFs are expressed as reciprocal dose. The GAFs, dermal SFs, and RfDs for the COPC are presented in Table M-3.

M.4.4 Sources of Toxicity Information Used in the Risk Assessment

M.4.4.1 Toxicity Values Selection of toxicity values is discussed in detail in Attachment 2 to this Appendix. Generally, they are chosen using the following hierarchy:

• EPA's on-line IRIS database (EPA, 1999) containing toxicity values that have undergone the most rigorous Agency review

• The latest version of the annual HEAST, including all supplements (EPA, 1997)

• Other EPA documents, memoranda, or former Environmental Criteria and Assess- ment Office or National Center for Environmental Assessment (NCEA) derivations for the Superfund Technical Support Center.

P\R15K2\m»iAN«fUAKW3UAM2\SEC2WPD. 07-27-99(2:56 pm) M-23 All toxicity values, regardless of their source, are evaluated for appropriateness for use in HHRA. When toxicity values are not located, the primary literature is surveyed to derive a toxicity value. The use of surrogate chemicals is also considered, if the chemical structure, adverse effects, and toxic potency of the surrogate and chemical of interest are sufficiently similar.

M.4.4.2 Gastrointestinal Absorption Factors GAFs used to derive dermal RfD values and SFs from the corresponding oral toxicity values, are obtained from the following sources:

• EPA's on-line IRIS database (EPA, 1999)

• Oral absorption efficiency data compiled by the NCEA for the Superfund Health Risk Technical Support Center of the EPA

• Federal agency reviews of the empirical data, such as Agency for Toxic Substances and Disease Registry Toxicological Profiles and various EPA criteria documents

• Other published reviews of empirical data

• Primary literature.

GAFs obtained from reviews are compared to empirical (especially more recent) data, when possible, and are evaluated for suitability for use for deriving dermal toxicity values from oral toxicity values. The suitability of the GAF increases when the following similarities are present in the oral pharmacokinetic study from which the GAF is derived and in the key toxicity study from which the oral toxicity value is derived:

• The same strain, sex, age, and species of test animal were used.

• The same chemical form (e.g., the same salt or complex of an inorganic element or organic compound) was used.

• The same mode of administration (e.g., diet, drinking water, or gavage vehicle) was used.

• Similar dose rates were used.

The most defensible GAF for each chemical is used in the HHRA.

P.VRISK2\HUMAN\GUAM«3UAM2\SEC2WPD, 07-27-99(2:56 pm) M-24 When quantitative data are insufficient, a default GAF is used. As noted by EPA (1989a), the gastrointestinal absorption of many metals is limited, and 0.05 is a reasonable default for metals. EPA (1989a) did not recommend a default value for organic chemicals. A compilation of data for 19 organic chemicals presented gastrointestinal absorption efficiencies ranging from 0.5 to 1.0 (Jones and Owen, 1989). All but three of these chemicals had absorption efficiencies of at least 0.9, indicating that organic chemicals are generally readily absorbed. The arithmetic average of the absorption efficiencies for the 19 organic chemicals, 0.91368 (equivalent to 0.9 when rounded to one significant figure), appears to be a reasonable default GAF for organic chemicals, and is used when quantitative data are insufficient.

M.5 Risk Characterization Risk characterization combines the results of the exposure assessment and toxicity assessment to yield quantitative expressions of risk for each of the receptor scenario evaluated in the HHRA. Quantitative estimates are developed for individual chemicals, exposure pathways, and exposure media for each receptor. The results of the risk characterization are presented as quantitative expressions of cancer risk and noncancer hazard. The risk characterization is used to guide risk management decisions.

Generally, the risk characterization follows the methodology prescribed by the EPA (1989a), as modified by more recent information and guidance cited in Section M.I of this document. The EPA methods are, appropriately, designed to be health-protective, and tend to overestimate, rather than underestimate, risk. Risk results are generally highly conservative, because risk characterization involves multiplication of the conservatisms built into the estimation of source- term and exposure-point concentrations, the exposure (intake) estimates, and the toxicity dose- response assessments.

M.S. 1 Risk Characterization Methodology Although some chemicals induce both cancer and noncancer effects, the risks for each type of effect are calculated separately for each receptor and each site. The COPC identified at Harmon Substation in Table M-l may present carcinogenic risk and/or noncancer hazards to the receptors discussed above.

M.5.1.1 Cancer Effects of Chemicals The risk of exposure to potential chemical carcinogens is estimated as the probability of an individual developing cancer over a lifetime. In the low-dose range, which would be expected for

P \RJSK2\HUMAN\GUAM«3UAM2\SEC2 WPD. 07-27-99(2:56 pm) M-25 most environmental exposures, cancer risk is estimated from the following linear equation (EPA, 1989a):

= (CDI)(SF) where.

ILCR = incremental lifetime cancer risk, a unitless expression of the probability of developing cancer, adjusted for background incidence CDI = chronic daily intake, averaged over 70 years (mg/kg-day) SF = cancer slope factor (mg/kg-day)"1.

The use of the preceding equation assumes that chemical carcinogenesis does not exhibit a threshold, and that the dose-response relationship is linear in the low dose range. Because this equation could generate theoretical cancer risks greater than 1 for high dose levels, it is consid- ered to be inaccurate at cancer risks greater than 1 x 10"2. In these cases, cancer risk is estimated by the "one-hit model" (EPA, 1989a):

where:

ILCR = incremental lifetime cancer risk, a unitless expression of the probability of developing cancer, adjusted for background incidence e-(CDixsF) _ tne exponential of the negative of the risk calculated in the equation above

As a matter of policy, the EPA (1986) considers the carcinogenic potency of simultaneous exposure to low doses of carcinogenic chemicals to be additive, regardless of the chemical's mechanisms of toxicity or sites (organs of the body) of action. Cancer risk arising from simulta- neous exposure by a given pathway to multiple chemicals is estimated from the equation (EPA, 1989a):

Riskp =/LCR(c/wrf) +/LCR{c/)enC) + ..JLCR(chen1} where:

Risk,, = total pathway risk of cancer incidence ILCR(chemi) = individual chemical cancer risk.

P \R3Sia\HUMANiGUAMVC}UAM2^EC2.\WPD. 07-27-99(236 pm) M-26 Cancer risk for a given receptor across pathways and across media is summed in the same manner.

The site-specific residential risk characterization for Harmon Substation was completed for the selected COPCs, through first dividing the source-term concentration by the PRG (EPA, 1998), and second multiplying the quotient by the target risk (10"*) for the appropriate COPC. Relying on the Region IX residential PRG value and a target risk level of 10"* ensures the derivation of highly conservative cancer and noncancer risk values for the combined child and adult resident. These values will adequately protect either on- or off-site residents in the vicinity of Harmon Substation.

M.5.1.2 Noncancer Effects of Chemicals The hazards associated with the noncancer effects of chemicals are evaluated by comparing an exposure level or intake with a RfD. The HQ, defined as the ratio of intake to RfD, is defined as (EPA, 1989a): HQ = HRJD where:

HQ = hazard quotient (unitless) I = intake of chemical (mg/kg-day) RfD = reference dose (mg/kg-day).

This approach is different from the probabilistic approach used to evaluate cancer risks. An HQ of 0.01 does not imply a 1 in 100 chance of an adverse effect, but indicates that the estimated intake is 100 times lower than the RfD. An HQ of unity indicates that the estimated intake equals the RfD. If the HQ is greater than unity, there may be concern for potential adverse health effects.

In the case of simultaneous exposure of a receptor to several chemicals, an HI is calculated as the sum of the HQs by (EPA, 1989a):

HI=/, /RfD, +I2/RfD2 +... where:

P:

If HI for a given pathway exceeds 1.0, individual HI values are calculated for each target organ

M.5.2 Risk Characterization Results Cancer and noncancer risk from total soil at Harmon Substation was characterized separately for the groundskeeper, trespasser, and resident receptor scenarios. Cancer risk is reported as an incremental lifetime cancer risk (ILCR) value and noncancer risk is reported as a HI value. The ILCR and HI are reported by receptor scenario for each COPC in Tables M-4 through M-6 Table M-7 provides a summary of total site JLCRs and His from Harmon Substation, for all the potential risk characterized receptor in Tables M-4 through M-6..

M.5.2.1 Cancer Risk Cancer risk from Harmon Substation, as it currently exists, is within acceptable risk limits for AAFB. Total site ILCR for each of the three COPC selected for Harmon Substation are below the recommended EPA target risk level of 1 x 10"* for each of the receptors evaluated. The only COPC that marginally approaches a point of interest is dioxin (WHO TEQ), for the resident receptor scenario. The resident scenario has an ILCR of 3.63 x 10"6 for dioxin TEQ, and an ILCR of 3.98 x 10-6 for the total site. The total site ILCR is 8.67 x 10-7 for the groundskeeper and 3.10 x 10-6 for the trespasser.

M.5.2.2 Noncancer Hazard Noncancer hazard from Harmon Substation, as it currently exists, is within acceptable risk limits for AAFB. The PCB Aroclor 1254 is the only COPC selected for Harmon Substation with published hazard toxicity values. Total site HI for Aroclor 1254 is well below the AAFB target- level HI of 1.0 for each of the receptor scenarios evaluated. Total site HI are 4.46 x 10-4 for the groundskeeper, 5.16 x 10-5 for the trespasser, and 5.64 x 10-3 for the resident.

M.6 Uncertainty Evaluation

M.6.1 Uncertainty Terminology Generally, risk assessments carry two types of uncertainty. Measurement uncertainty refers to the usual variance that accompanies scientific measurements, e.g., instrument uncertainty (accuracy and precision) associated with chemical concentrations. The results of the risk assessment reflect

P \RISK2\HUMAN\GUAM\GUAM2\SECZVVPD, 07-27-99(2 56 pm) M-28 Table M-4

Groundskeeper Intake Doses and Risk Hazard Estimates for Exposure to Total Soil IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

(Page 1 of 2)

Inhalation of COPC Source-Term Concentration in Dust from Total Soil Concentration in Air Cancer Noncancer ILCR from HQ from 3 Chemical (mg/kg) (mg/m ) (mg/kg-day) (mg/kg-day) Inhalation Inhalation

Dioxin Dioxin TEQ 1.38E-05 1.38E-12 9.62E-14 2.69E-13 1.06E-08 NA PAH Benzo(a)pyrene 1.66E-02 1.66E-09 1.16E-10 3.25E-10 3.60E-10 NA PCB Aroclor 1254 5.47E-03 5.47E-10 3.83E-11 1.07E-10 7.65E-11 NA

Total Pathway ILCR and HI 1.10E-08 NA

Total ILCR and HI

COPC * Chemical of potential concern TEQ = TCDD equivalent concentration for dioxins PAH - Polynuclear aromatic hydrocarbon PCB = Polychiorinated biphenyl ILCR = Incremental lifetime cancer risk HQ = Hazard quotient HI = Hazard index NA = Not applicable Table M-4

Groundskeeper Intake Doses and Risk Hazard Estimates for Exposure to Total Soil IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

(Page 2 of 2)

Ingestion of COPC Dermally Absorbed in Total Soil ILCR from HQ from Dose of COPC ILCR from HQ from Cancer Noncancer Incidental Incidental Cancer Noncancer Dermal Dermal Sum ILCR SUM HI Chemical (mg/kg-day) (mg/kg-day) Ingestion Ingestion (mg/kg-day) (mg/kg-day) Contact Contact

Dioxin Dioxin TEQ 4.81E-12 1.35E-11 7.22E-07 NA 4.81E-13 1.35E-12 8.02E-08 NA 8.13E-07 NA PAH Benzo(a)pyrene 5.81 E-09 1.63E-08 4.24E-08 NA 5.81E-10 1.63E-09 8.48E-09 NA 5.12E-08 NA PCB Aroclor 1254 1.91E-09 5.36E-09 6.50E-10 2.68E-04 1.15E-09 3.21E-09 2.55E-09 1.79E-04 3.28E-09 4.48E-04

Total Pathway ILCR and HI 7.65E-07 2.68E-04 9.12E-08 1.79E-04

Total ILCR and HI 8.87E-07 4.46E-04

COPC = Chemical of potential co TEQ = TCDD equivalent concentr PAH = Polynuclear aromatic hydr PCB - Polychiorinated blphenyl ILCR = Incremental lifetime cane HQ - Hazard quotient HI = Hazard index NA = Not applicable

\Ou«ii\RevmevlDi*lMlml*3-1 «h\M-4 gmftpVW/W (3 03 PMytW Table M-5

Trespasser Intake Doses and Risk Hazard Estimates for Exposure to Total Soil IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

(Pagel of 2)

Inhalation of COPC Source-Term Concentration In Total Soil Concentration in Air Cancer Noncancer ILCR from HQfrom Chemical (mg/kg) (mg/m3) (mg/kg-day) (mg/kg-day) Inhalation Inhalation

Dioxin Dioxin TEQ 1.38E-05 9.26E-15 3.34E-17 2.34E-16 3.68E-12 NA PAH Benzo(a)pyrene 1.66E-02 1.12E-11 4.03E-14 2.82E-13 1.25E-13 NA PCB Aroclor 1254 5.47E-03 3.68E-12 1.33E-14 9.30E-14 2.66E-14 NA

Total Pathway ILCR and HI 3.83E-12 NA

Total ILCR and HI

COPC = Chemical of potential concern TEQ = TCDD equivalent concentration for dioxins PAH = Polynuclear aromatic hydrocarbon PCB = Polychiorinated blphenyl ILCR = Incremental lifetime cancer risk HQ s Hazard quotient HI = Hazard index NA = Not available

P.\IUsK\Hiimm\Gti«m\RCTl Wev Table M-5

Trespasser Intake Doses and Risk Hazard Estimates for Exposure to Total Soil IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

(Page 2 of 2)

Ingestion of COPC Dermally Absorbed In Total Soil ILCR from HQfrom Dose of COPC ILCR from HQfrom Cancer Noncancer Incidental Incidental Cancer Noncancer Dermal Dermal Sum ILCR SUM HI Chemical (mg/kg-day) (mg/kg-day) Ingestion Ingestion (mg/kg-day) (mg/kg-day) Contact Contact

Dioxin Dioxin TEQ 1.56E-13 1.09E-12 2.34E-08 NA 3.23E-14 2.26E-13 5.38E-09 NA 2.87E-08 NA PAH Benzo(a)pyrene 1.88E-10 1.31E-09 1.37E-09 NA 3.89E-11 2.72E-10 5.68E-10 NA 1.94E-09 NA PCB Aroclor 1254 6.19E-11 4.33E-10 1.24E-10 2.17E-05 7.70E-11 5.39E-10 1.71E-10 2.99E-05 2.95E-10 B.16E-05

Total Pathway ILCR and HI 2.48E48 2.17E-05 6.12E-09 2.99E-OS

Total ILCR and HI 3.10E-08 S.16E-05

COPC = Chemical of potential con TEQ » TCDD equivalent concentrat PAH = Polynuclear aromatic hydro PCB = Polychiorinated biphenyl ILCR - Incremental lifetime cancer HQ = Hazard quotient HI = Hazard index NA = Not available

PAWik3\Hlmwi\O»ro\Rev|\R^IDnifl\Tt>iTllft3-7jtIi\M-5 TispnVMT/M (3 03 PMVDO Table M-6

Residential Intake Doses and Risk Hazard Estimates for Exposure to Total Soil IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

EPA Region 9 Source-Term Residential Soil PRG Concentration Residential Chemical pg/kg Mg/kg ILCR HI

Dioxin Dioxin TEQ 3.80E-03 1.38E-02 3.63E-06 NA PAH Benzo(a)pyrene 5.60E+01 1.66E+01 2.96E-07 NA PCB Aroclor 1254 9.70E+01 5.47E+00 5.64E-08 5.64E-03

TOTAL * 3.98E-06 5.64E-03

PRG = Preliminary remediation goal TEQ = TCDD equivalent concentration for dioxins PAH = Polynuclear aromatic hydrocarbon PCB = Polychiorinated biphenyl ILCR = incremental lifetime cancer risk HI = Hazard index NA = Not available

P:\Rltl(2\Human\Ou»m\Rev1«av10ram\Tbm1*3-rjd8\M-6 Res\7/27/99 (3:M PM)/DO Table M-7

Summary of Risks and Hazards from Total Soil IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

Total Sile Total Site Receptor ILCR HI Groundskeeper 8.67E-07 4.46E-04 Trespasser 3.10E-08 5.16E-05 Resident 3.98E-06 5.64E-03

ILCR * Incremental lifetime cancer risk HI* Hazard index

mmm the accumulated variances of the individual measured values used to develop it. A different kind of uncertainty, called informational uncertainty, stems from data gaps, i.e., the fact that additional information is needed to complete the database for the assessment. Often the data gap is significant, such as the absence of information on the effects of human exposure to a chemical or on the biological mechanism of action of an agent (EPA, 1992c).

Reliance on a simplified numerical presentation of dose and risk without consideration of uncertainties, limitations, and assumptions inherent in the assessment process can be misleading. For example, a lifetime cancer risk of 10"* may be calculated for a given exposure scenario. However, if the uncertainty in this estimate is several orders of magnitude, the real risk may be higher than the risk from another scenario that has a calculated lifetime risk of cancer of 10'5 but a smaller degree of uncertainty.

Alternatively, a lifetime cancer risk of 10~2 may be calculated and appear to represent an unaccep- table risk. The actual risk, however, may be one, two, or even three orders of magnitude smaller. Situations like this occur frequently, because the estimated risk reflects conservative assumptions on lifestyles and land-use scenarios, maximum or near-maximum values for almost all modeling and exposure variables, limited information and uncertainty in the calculational parameters, and conservative assumptions in the toxicity value derivations.

M.6.2 Sources of Uncertainty As noted previously, uncertainties are associated with the information and data used in each phase of the HHRA. Uncertainties associated with information and data are evaluated in this section to provide a sound, balanced basis for evaluating the overall quality of the risk assessment results. Sources of uncertainty, as well as the direction of bias that results (i.e., whether conservatism is increased or decreased) are presented in the following sections.

M.6.2.1 Selection and Quantification of COPC Uncertainty associated with the selection process used to determine the COPC and estimation of source-term concentrations arises from the following:

• Estimated source-term concentrations are uncertain. For statistical purposes, if a chemical is positively identified at a site and has at least a single positive hit, all the samples with nondetects are assumed to have a value equal to half the detection limit and are included in the data set. These procedures introduce a conservative bias into the risk assessment.

P:\RISK2\HUMANVSUAMtf5UAM2\SEC2 WHO, 07-27-99(2:56 pm) M-29 • Soil in the area is heterogeneous in nature. The direction of bias is unclear.

• Limited number of samples results in the calculation of wide confidence intervals on the mean concentration and high source-term concentrations. Where the 95 percent UCL exceeded the maximum value, the maximum value was chosen as the source- term. The use of elevated confidence limits imparts a conservative bias upon the risk assessment.

• Laboratory analytical techniques have a degree of uncertainty associated with them. These uncertainties are documented by using data qualifiers to reflect the degree of certainty of measurement. The direction of bias is unclear.

• UCLs are used for source-term concentrations according to EPA (1989a). This means that 95 percent of the time, the actual mean concentration can be less than the value used in the exposure assessment. Conversely, 5 percent of the time, the actual mean concentration can be greater than the value used in the exposure assessment. Therefore, the exposure assessment may underestimate the exposures in 5 percent of the cases, and overestimate exposures 95 percent of the time, imparting an overall conservative bias to the risk assessment.

M.6.2.2 Estimation of Modeled Exposure Point Concentrations Uncertainty associated with the modeled exposure point concentrations arises from calculating air concentrations. Uncertainty is introduced hi the form of a dust-loading factor that converts chemical concentrations in soil to concentrations in air. In general, fate and transport modeling imparts a conservative bias upon the risk assessment.

M.6.2.3 Selection of Hypothetical Receptors and Potential Exposure Pathways Generally, the hypothetical receptors and exposure pathways are chosen to "cover" the most highly exposed individual or subpopulation, introducing a conservative bias to the risk results.

M.6.2.4 Quantification of Intakes Ingestion rates, inhalation rates, exposure durations, and exposure frequencies are based on upperbound values (EPA, 1991b), even though it is well established that serial multiplication of ultraconservative variable values lead to gross overestimation of chemical intakes.

M. 6.2.5 Toxicity Assessment Considerable uncertainty is associated with the qualitative (hazard assessment) and quantitative (dose-response) evaluations of a toxicity assessment. Hazard assessment of carcinogenicity is evaluated as a weight-of-evidence determination (EPA, 1986). Positive animal cancer test data

P \RJSK2'OHUMAN\GUAlvrvGUAM2«ECTWPD. 07-27-99(2:S6 pm) M-3 0 suggest that humans also contain tissue(s) that may manifest a carcinogenic response; however, the animal data cannot necessarily be used to predict the target tissue in humans. In the hazard assessment of noncancer effects, however, positive animal data suggest the nature of the effects (i.e., the target tissues and type of effects) anticipated in humans (EPA, 1989b).

Uncertainty in hazard assessment arises from the nature and quality (sensitivity and selectivity) of the animal and human data. Uncertainty is decreased when similar effects are observed across species, strain, sex, and exposure route; when the magnitude of the response is clearly dose- related; when pharmacokinetic data indicate a similar fate in animals and humans; when postulated mechanisms of toxicity are similar for humans and animals; and when the COPC is structurally similar to other chemicals for which the toxicity is more completely characterized.

There are many sources of uncertainty in the dose-response evaluation for cancer (i.e., com- putation of a slope factor or unit risk) and noncancer effects (i.e., computation of an RfD). First is the uncertainty regarding interspecies (animal-to-human) extrapolation, which, in the absence of quantitative pharmacokinetic, dosimetric, or mechanistic data, is usually based on consideration of interspecies differences in basal metabolic rate. Second is the uncertainty regarding intraspecies, or individual, variation. Most toxicity experiments are performed with animals that are very similar in age and genotype, so that intragroup biological variation is minimal, but the human population of concern may reflect wide heterogeneity, including unusual sensitivity to the COPC. Even toxicity data from human groundskeeper exposure reflect a bias because only those individuals sufficiently healthy to attend work regularly and those not unusually sensitive to the COPC are likely to be occupationally exposed. Third, uncertainty arises from the quality of the key study (from which the quantitative estimate is derived) and the database. For cancer effects, the uncertainty associated with some quality factors (e.g., group size) is expressed within the 95 percent upper bound of the SF. For noncancer effects, additional uncertainty factors may be applied in the derivation of the RfD to reflect poor quality of the key study or gaps in the database.

Another source of uncertainty regarding quantitative risk estimation for carcinogenicity is the method by which data from high doses in animal studies are extrapolated to the dose range expected for environmentally exposed humans. The linearized multi-stage model, which is used in nearly all quantitative estimations of human cancer risk from animal data, is based on a non- threshold assumption of carcinogenesis. An impressive body of evidence, however, suggests that epigenetic carcinogens, as well as many genotoxic carcinogens, have a threshold below which

P \WSK2\HUMAWGUA1*GUAM2\SECZWPD. 07-27-99(2:56 pm) M-31 they are noncarcinogenic (EPA, 1996b); therefore, the use of the linearized multi-stage model is ultraconservative for chemicals that exhibit a threshold for carcinogenicity.

A further source of uncertainty for noncancer effects arises from use of an effect level in the estimation of an RfD or RfC, because this estimation is predicated on the assumption of a threshold below which adverse effects are not expected. Therefore, an additional uncertainty factor is usually applied to estimate a no-effect level. Additional uncertainty arises from estima- tion of an RfD for chronic exposure from less-than-chronic data. Unless empirical data indicate that effects do not worsen with increasing duration of exposure, an additional uncertainty factor is applied to the no-effect level in the less than chronic study. Uncertainty also arises from the presence of chemicals (e.g., lead) for which there are no EPA-approved toxicity values, and for which quantitative risk characterization is not possible. In this case, however, lead concentrations in soil are clearly below those that might be associated with adverse effects (EPA, 1994c).

M.6.2.6 Risk Characterization Risk characterization is the process of quantifying the risk of cancer due to exposure to carcino- gens. Following EPA (1989a) guidelines, this assessment uses the one-hit model to estimate risk. However, there is uncertainty associated with the one-hit model, and with other risk models, because most studies of carcinogenic effects provide limited dose-response information for risk estimation (ICRP, 1990).

This effort to identify potential uncertainties associated with each step of the risk assessment is not intended to discredit the calculated results, but to point out that risks are calculated for hypothetical receptors under a definite, strict method. Refinements of sampling plans, analytical techniques, data statistical evaluation, exposure assessment models and parameters, hazard evaluation, dose-response assessment, and risk characterization could reduce these uncertainties.

M.6.3 Site Specific Uncertainty Additional uncertainty exists that is related to site-specific variables and factors. Typically, there is statistical uncertainty associated with smaller numbers of samples. In general, where the number of samples is less than approximately 30, statistical confidence will be low, and complimentary uncertainty will be relatively high. In this HHRA uncertainty related to sample size is minimal due to the relatively large number of samples (n = approximately 80) collected and analyzed for this relatively small (9 acre) IRP She. Uncertainty may also result from data gaps associated with horizontal or vertical gaps in the spatial distribution of sample locations. Again, sampling of the

?:\MSK2\HUMANVC5UAM\GUAM2\SECZ\VED. 07-27-99(2:56 pm) M-32 Harmon Substation IRP was extensive and thorough (see Sections 2 and 3, above). Thus uncertainty associated with spatial sampling data gaps should be minimal.

Potentially significant uncertainty could exist with respect to potential future hunting and game meat consumption associated with AAFB IRP sites. At present it is believed that hunting of wild pigs and deer does not take place at Harmon Substation, however the more significant question is; what contribution will COPC in soil at Harmon Substation make to tissue in deer and wild pig across AAFB? And, how much of that game meat will eventually be ingested by humans? More extensive tissue sampling and modeling would be needed to answer these questions with certainty Of particular concern is the potential for biotransfer of dioxin and PCB to humans, from pig tissue uptake associated with pig rooting activities at the site. However, at Harmon Substation, it is reasonable to assume that additional modeling will not reveal significant additional risk, because the source term concentrations for PCB and dioxin and associated risk to human health from Harmon Substation are relatively low (see Tables M-l and M-4 through M7), and the site is relatively small.

Another potential site-specific source of uncertainty that may have impacted the characterization of risk from Harmon Substation, relates to the movement of site soils following the completion of sampling activities at the site. In general, post-remedial (and post-sampling) backfilling opera- tions at the site should have helped to reduce risk from site soil through making what little contamination there is at Harmon Substation even less accessible than it was prior to backfilling operations. However, there is a very slight chance that backfilling activities could have brought additional contaminated soil to the surface. This would have increased potential for human exposure to COPC at the site.

In conclusion, site-specific uncertainty at Harmon Substation appears to be within reasonable limits. This conclusion is supported by the relatively low concentrations of COPC in soil remaining at the site, and associated relatively low human health risk levels demonstrated in Table M-7.

M.7 Summary of the Baseline Human Health Risk Assessment A HHRA was performed following the methodology of EPA (1989a) and subsequent EPA (Region IX) guidance (EPA, 1998). Risk from Harmon Substation was characterized for three hypothetical receptors; a groundskeeper, a trespasser, and a resident. Each of these receptors was

P\RISK2\HlttlANV3UAM«JUAM2VSEC2.WPD. 07-27-99(2 56 pm) M-3 3 theoretically exposed to total soil at Harmon Substation. According to the results of this HHRA, both total site ILCR and total site HI for Harmon Substation are within acceptable risk limits.

M.8 References Andersen Air Force Base (AAFB), 1997, Final Basewide Quality Assurance Project Plan (QAPP), October.

Gilbert, R. O., 1987, Statistical Methods for Environmental Pollution Monitoring, Van Norstrand, New York, New York.

ICF Kaiser, Inc., 1999, Final Environmental Engineering/Cost Analysis Report, IRP Site 16/Landfill 21,Mzy.

International Commission for Radiological Protection (ICRP), 1990,1990 Recommendations of the International Commission for Radiological Protection, ICRP Publication 60.

Jones, TD. and BA Owen, 1989, Health Risks from Mixtures ofRadionuclides and Chemicals in Drinking Water, Oak Ridge National Laboratory, Oak Ridge, TN, ORNL-6533.

Land, C. E., 1975, "Tables of Confidence Limits for Linear Functions of the Normal Mean and Variance," in Selected Tables in Mathematical Statistics, Vol. IE, American Mathematical Society, Providence, Rhode Island.

National Council on Radiation Protection and Measurements (NCRP), 1984, Radiological Assessment: Predicting the Transport, Bioaccumulation, and Uptake by Man ofRadionu- clides Released to the Environment, NCRP Report No. 76.

Statsoft, Inc., 1995 STATISTICA ™for Windows, Computer Program Manual, Tulsa, Oklahoma.

U.S. Department of Energy (DOE), 1989, A Manual for Implementing Residual Radioactive Material Guidelines, Argonne National Laboratory, Argonne, Illinois, ANL/ES-160, DOE- /CH/8901.

U.S. Environmental Protection Agency (EPA), 1999, Integrated Risk Information System (IRIS), National Center for Environmental Assessment, Cincinnati, OH, on line.

U.S. Environmental Protection Agency (EPA), 1998, Region 9 Preliminary Remediation Goals (PRGs) 1998, online, http://www.epa.gov/region 09/.

U.S. Environmental Protection Agency (EPA), 1997, Health Effects Assessment Summary Tables, FY1997 Update, Office of Solid Waste and Emergency Response, Washington, DC, 9200.6-303(97-1), EPA 540/R-97-036, PB97-921199.

PVRISK2\HUMAN\GUAK.flGUAM2\SEC2.WTO. 07-27-99(2:56 pm) M-34 U.S. Environmental Protection Agency (EPA), 1996a, Soil Screening Guidance: Technical Background Document, Office of Solid Waste and Emergency Response, EPA/540/R-95/128, NTIS No. PB96-963"502.

U.S. Environmental Protection Agency (EPA), 1996b, Soil Screening Guidance: Users Guide, Office of Solid Waste and Emergency Response, Washington, DC, Publication 9355.4-23, April.

U.S. Environmental Protection Agency (EPA), 1995, Supplemental Guidance to RAGS: Region 4 Bulletins, Human Health Risk Assessment (Interim), Waste Management Division, Office of Health Assessment, EPA Region 4, Atlanta, GA, November.

U.S. Environmental Protection Agency (EPA), 1994a, Test Methods for Evaluating Solid Waste, Update D, SW-846, Office of Research and Development, Washington, DC.

U.S. Environmental Protection Agency (EPA), 1994b, Contract Laboratory Program National Functional Guidelines for Inorganic and Organic Data Review, Office of Research and Development, Washington, DC.

U.S. Environmental Protection Agency (EPA), 1994c, Guidance on Residential Lead-Based Paint, Lead-Contaminated Dust, and Lead-Contaminated Soil, Memorandum from L. R. Goldman, Assistant Administrator, to EPA Regional Directors, July 14, 1994.

U.S. Environmental Protection Agency (EPA), 1992a, Supplemental Guidance to RAGS: Calculating the Concentration Term, Interim Final, Office of Emergency and Remedial Response, Washington, DC, Publication 9285.7-081.

U.S. Environmental Protection Agency (EPA), 1992b, Dermal Exposure Assessment: Princi- ples and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, including Supplemental Guidance August 18, 1992.

U.S. Environmental Protection Agency (EPA), 1992c, Guidance on Risk Characterization for Risk Managers and Risk Assessors, Memorandum from F. Henry Habicht II, Deputy Adminis- trator, to Assistant Administrators, Regional Administrators, February 26.

U.S. Environmental Protection Agency (EPA), I992d, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, January.

U.S. Environmental Protection Agency (EPA), 1991a, Risk Assessment Guidance for Super- fund: Volume I—Human Health Evaluation Manual (PartB, Development of Risk-based Preliminary Remediation Goals), Including Revisions to Chapter 4 (November 1992), and Appendix D: Corrections to RA GS-Part B Sections 3.3.1 and 3.3.2 (April 1993), Office of Emergency and Remedial Response, Washington, DC. Publication 9285.7-0IB.

P.«1SK2\HUMAN\GUAM\GUAM2«EC2\MRD. 07-27-99(2 36pm) M-3 5 U.S. Environmental Protection Agency (EPA), 1991b, Risk Assessment Guidance for Super- fund Volume I: Human Health Evaluation Manual Supplemental Guidance ^Standard Default Exposure Factors,' Interim Final, Office of Solid Waste and Emergency Response, OSWER Directive: 9285.6-03.

U.S. Environmental Protection Agency (EPA), 1990, Exposure Factors Handbook, Office of Health and Environmental Assessment, Washington, DC, EPA/600/8-89/043.

U.S. Environmental Protection Agency (EPA), 1989a, Risk Assessment Guidance for Super- fund, Volume I, Human Health Evaluation Manual (Part a), Interim Final, Office of Emer- gency and Remedial Response, Washington, DC, EPA/540/1-89/002.

U.S. Environmental Protection Agency (EPA), 1989b, General Quantitative Risk Assessment Guidelines for Noncancer Health Effects, Prepared by the Office of Health and Environmental Assessment, Cincinnati, Ohio for the Risk Assessment Forum, ECRAO-CIN-538.

U.S. Environmental Protection Agency (EPA), 1986, "Guidelines for Carcinogen Risk Assess- ment", Federal Register, 51(185): 33992-34003.

P \IUSK2\HUMAN\GUAM\GUAM2\SEC3.WED. 07-27-99(2.56 pm) M-3 6 Appendix M: Attachment 1

Data Used to Complete Confirmation HHRA

IRP Site 39/Harmon Substation Andersen Air Force Base, Guam

Appendix M: Attachment 2

Toxicological Profiles for Chemicals of Potential Concern

IRP Site 39/Harmon Substation Andersen Air Force Base, Guam lexicological profiles are brief descriptions of the nature of the adverse effects associated with the COPCs selected for evaluation because their concentrations in one or more environmental media exceed a very conservatively derived risk-based screening concentration. It is important to note that a discussion of adverse effects without a discussion of dose is incomplete and potentially misleading, because virtually any chemical may be toxic at some dose, and many chemicals (e.g., nutritionally required minerals, vitamins, amino acids, etc.) enhance human health at some low dose. An ever growing and compelling body of evidence suggests that many environmental contaminants also enhance health at low doses (Hart and Frame, 1996).

When sufficient data are available, the EPA Integrated Risk Information System (IRIS) presents the EPA's Reference Dose (R£D)/Reference Concentration (RfC) Work Group-verified chronic toxicity values for threshold, or noncancer, effects, and the Carcinogen Risk Assessment Verification Endeavor (CRAVE) Work Group-verified toxicity values for cancer risk (EPA, 1999). The toxicity values for noncancer effects include an RfD expressed in milligrams per kilogram per day (mg/kg-day) for chronic oral exposure, and a RfC, in milligrams per cubic meter (mg/m3), for chronic inhalation exposure. The inhalation RfC in units of mg/m3 may be converted to an equivalent inhalation RfD by assuming continuous chronic exposure of humans with a body weight of 70 kg and an inhalation rate of 20 nrVday. In other words, the RfC expressed as mg/m3 is multiplied by the inhalation rate of 20 rnVday, and the result is divided by the body weight of 70 kg to yield an inhalation RfD expressed as mg/kg-day.

RfDs and RfCs are usually derived from empirical benchmark doses (BMD) or concentrations called no-observed-effect levels (NOEL) or no-observed-adverse-effect levels (NOAEL) from animal toxicity or human epidemiology studies. If the data do not permit identifying a NOEL or NOAEL, a lowest-observed-adverse-effect level (LOAEL) or lowest-effect level (LEL) may be used. A frank-effect level (PEL), e.g., mortality, shortened life span or serious neurologic or behavioral disturbances, is generally considered an inappropriate benchmark from which to develop an RfD or RfC. Some RfD and RfC derivations employ a BMD that is a statistically estimated dose for humans at which some low proportion of the population may experience some minimally adverse effect. A BMD at which 10 percent of the population may be expected to respond is expressed as BMD10. The RfD or RfC is derived by dividing the benchmark level (e.g., NOAEL or BMDi0) by a series of uncertainty and modifying factors, collectively designated the uncertainty factor 0JF).

For cancer effects, IRIS presents an EPA cancer weight-of-evidence group classification that reflects qualitatively the likelihood that the chemical is carcinogenic to humans. IRIS also presents a slope factor (SF) for oral exposure, expressed as the risk per mg/kg-day ingested dose, and a unit risk factor (URF) for inhalation exposure, expressed as the risk per ug/m3 in ambient air. These quantitative estimates are generally provided for chemicals in EPA weight-of-evidence Groups A and B and C, if the data are adequate. The SF or URF is usually estimated as an upper bound on the slope of the dose- or concentration-response curve from animal toxicity or human epidemiology studies. The inhalation URF in units of risk per ug/m3 may be converted to an equivalent inhalation SF in units of risk per mg/kg-day by assuming continuous lifetime exposure of humans with a body weight to 70 kg and an inhalation rate of 20 nrVday. In other words, the URF expressed as risk per ug/m3 is divided by the inhalation rate of 20 mVday, and multiplied by the assumed body weight of 70 kg and a conversion factor of 1000 Lig/mg.

P \RJSKnHUMANNGUAMVGUAMI\ATTACHlWPD. 7/77/MCHtf fa) 1 Toxicity values are not estimated for acute toxicity and acute exposure is not evaluated in the risk assessment. Nonetheless, the levels associated with acute lethality and data regarding the effects of acute exposure to levels higher than ordinarily observed in chronic environmental exposure provide additional perspective regarding the toxicity of the chemical. Therefore, this information is usually included in the profiles. Lethality data for laboratory animals are generally expressed as the oral dose associated with lethality of 50 percent of a test group (LDM) or the concentration in air associated with lethality of 50 percent of a test group (LCjo). Occasionally the dose associated with lethality in a low percentage of exposed individuals (LD^ ) is presented.

The toxicity profiles may also provide documentation for physical constants that are important for chemical transport modeling, such as molecular weight (MW) in grams per mole (g/mole), the log of the octanol/water partition coefficient (log K^), Henry's law constant (H) in atmosphere-cubic meter/mole (atm-mVmole), the soil/water partition coefficient (Kj) in liters per kilogram (L/kg) for metals, the log of the soil/organic carbon partition coefficient (log K^) (unitless) for organic 2 chemicals, diffusivity in air (DJ in square centimeters per second (cm /s), diffusivity in water (Dw) hi cnrVs, vapor pressure (VP) in atmospheres (atm), and solubility in water (S) in milligrams per liter (mg/L). In addition, organic chemicals are designated as volatile organic compounds (VOC) or Semivolatile organic compounds (SVOC) based on their propensity to volatilize from environmental media. VOCs generally have a MW less than 200 g/mole and H greater than 1E-5 atm-mVmole (EPA, 1991).

The physical constants generally are taken from the most reliable source (i.e., the source that provides the highest level of documentation). Values for interrelated properties are usually taken from the same source (e.g., H is often estimated from VP and S; therefore, the same source is usually used for all three property values). When one source provides several values for a given property, professional judgement is used to select the most appropriate. Obvious outliers may be dropped from consideration. The average or the midpoint of a range of values may be selected. Kj values for metals and K^ values for ionizing organic compound are based on a default pH of 6.8 (EPA, 1996). VP and S values are limited to those provided for normal ambient temperatures (0 to 30°C), but the temperatures reported in the original sources for VP and S are not presented in the toxicity profile, nor is any attempt made to extrapolate W and S to any default temperature.

The toxicity profiles provide documentation for the gastrointestinal (Gl) absorption factor (GAF), which is used to develop the dermal RfD and SF, the dermal absorption factor (ABS), which describes the extent of dermal uptake from soil, and the permeability coefficient (PC) and tau (T), which are used to estimate the rate of dermal uptake from water. Usually PC and t are taken from EPA (1992), unless EPA (1992) provides no values, or professional judgement suggests that a log K,^ value other than the one provided by EPA (1992) is clearly more appropriate. In these cases, PC is calculated as follows (EPA, 1992):

F\WSK2\HUMANiGUAMVGUAM»ATrACHrWPD. 7/27/990** pm) where:

PC = permeability coefficient (cm/hour, calculated) log "K^ = log of the octanol/water partition coefficient (unitless) MW - molecular weight and T is calculated as follows (EPA, 1992):

6 • 10( ~2'72 ~°-0061 '^^ where:

T = time for concentration of contaminant in stratum corneum to reach steady state (hours, chemical-specific) LK = effective thickness of the stratum corneum (1E-3 cm) MW = molecular weight.

Biotransfer factors such as water-to-fish bioconcentration factors (BCF), soil-to-plant or plant-to- animal transfer factors are not included, because the method for their derivation may be EPA region-, program- or site-specific. Biota-sediment accumulation factors (BSAF) are included for the few SVOCs for which values are available.

References for Introductipn

Hart, R.W. and L.T. Frame, 1996, "Toxicological Defense Mechanisms and How They May Affect the Nature of Dose-Response Relationships," Biological Effects of Low Level Exposure (BELLE) Newsletter, 5(1): 1-16.

U.S. Environmental Protection Agency (EPA), 1991, Risk Assessment Guidance for Superfund: Volume I—Human Health Evaluation Manual (Part B, Development of Risk-Based Preliminary Remediation Goals), Interim, Office of Emergency and Remedial Response, Washington, DC, OSWER Publication 9285.7-01B.

U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, January.

U.S. Environmental Protection Agency (EPA), 1996, Soil Screening Guidance: Users Guide, Office of Solid Waste and Emergency Response, Washington, DC, Publication 9355.4-23, April.

U.S. Environmental Protection Agency (EPA), 1999, Integrated Risk Information System (IRIS), National Center for Environmental Assessment, Cincinnati, OH, on line.

P-\JUSK7«UMANV3UAMV3UAM2\ATTACH2 WPD. 7/77/99(3:06 pm) POLY AROMATIC HYDROCARBONS

The PAHs regularly observed in environmental media include acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthenes benzo(k)fluoranthene, benzo(g,h,i)perylene, carbazole, chrysene, dibenzo(a,h)anthracene, fluoranthene, fluorene, indeno(l,2,3-cd)pyrene, naphthalene, phenanthrene and pyrene. All are SVOCs except naphthalene, which is a VOC. PAHs are the products of incomplete combustion of fossil fuels or other organic matter, hence include both natural and anthropogenic sources (ATSDR, 1993a). The PAHs are ubiquitous, reflecting natural combustion, the widespread practice of fossil fuel combustion, and wide dissemination via wind currents. Relevant physical properties for selected PAH are compiled below:

MW logK^ H logK^ D. Dw VP S (g/mole) (unitless) (atm-mVmole) (unitless) (cm2/s) (cm2/s) (atm) (mgA-) Anthracene 178.2 4.45* 8.6E-5* 4.15* 3.24E-2' 7.74E-6* 2.2E-8* r Benzo(a)anthracene 228.29 5.66d 1E-6* 5.30* 5.10E-2C 9.00E-6' 2.9E-11* r Benzo(a)pyrene

252.3 6.16" 4.9E-7* 6.74' 4.30E-2* 9.00E-6C 7.4E-12* 3.8E-3* Benzo(b)fiuoranthene 252.3 6. 12* 1.22E-5* 5.74* 2.26E-2' 5.56E-6e 1.3E-91 r Benzo(k)fluoranthene. 252.3 6.06* 3.87E-51 5.74* 2.26E-2' 5.56E-6' 6.6E-101 r Chiysene 228.3 5.66d 1.05E-6* 5.30* 2.48E-2e 6.21E-6C 8.3E-12* r Dibenzo(a,h)anthracene

278.35 6.84" 7.3E-8* 6.52* 2.02E-2' 5.18E-6' 8.2E-12* 5E-7* Fluoranthene

202.26 4.95d 6.5E-61 4.58* 3.02E-2' 6.35E-6' 6.6E-9* 2.06E-1* Indeno(l ,2,3-cd)pyrene

276.3 6.58-1 6.95E-8* 6.20* 1.90E-2' 5.66E-6' 1.3E-12* 6.23E-2* Pyrene 202.3 4.88* 5.1E-6* 4.58* 2.72E-2' 7.24E-6e 3.3E-9* r MW logK.. H logK^ D. D. VP S (g/mole) (unitless) (atxn-ms/mole) (unitless) (cm'/s) (cmVs) (atm) (mg/L) ND = no data, I = virtually insoluble in water. •Agency for Toxic Substances and Disease Registry (ATSDR), 1993a, Update Toxicological Profile for Poly cyclic Aromatic Hydrocarbons (PAHs), Draft for Public Comment, U.S. Department of Health and Human Services, Atlanta, Georgia, October. bMontgomery, J.H., 1996, Groundwater Chemicals Desk Reference, Second Edition, Lewis Publishers, New York. CU.S. Environmental Protection Agency (EPA), 1996, Sot? Screening Guidance: Users Guide, Office of Solid Waste and Emergency Response, Washington, DC, Publication 9355.4-23, April. dU.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, January. 'U.S. Environmental Protection Agency (EPA), 1994, Technical Background Document for Soil Screening Guidance, Review Draft, Office of Solid Waste and Emergency Response, Washington, DC, Publication No. 9355.4-17, EPA540/R-94/106, PB95-963532, November. f Agency for Toxic Substances and Disease Registry, (ATSDR), 1993b, Update Toxicological Profile for Naphthalene, Draft for Public Comment, U.S. Public Health Service, Atlanta, Georgia, October.

Jones and Owen (1989) report that the Gl absorption of naphthalene is 100 percent. The GAF of 1.0 from the Jones and Owen (1989) compilation is adopted for naphthalene. Toxicokinetic studies of several PAHs summarized by ATSDR (1993a) provide limited quantitative information regarding the extent of Gl absorption. Qualitatively, these studies indicate that absorption is incomplete. A study of benzo(a)pyrene in rats suggested that Gl absorption ranges from 38 to 58 percent. The GAF of 0.5 (Jones and Owen, 1989), near the midpoint of the range from the rat study, is selected for benzo(a)pyrene and the other PAHs for which quantitative data are not available. A study in rats reported absorption efficiency for anthracene ranging from 53 to 74 percent; 0.7 is selected as the GAF for this evaluation. Gl absorption of pyrene, chrysene and dibenzo(a,h)anthracene is described as high; a GAF of 0.8 is assumed for these compounds.

Anecdotal evidence from using cloth diapers stored in contact with naphthalene indicates that naphthalene is absorbed by the skin, but quantitative data are not available (ATSDR, 1993b). Empirical data with pure compound dissolved or suspended in vehicles suggest that dermal uptake of benzo(a)pyrene is extensive (ATSDR, 1993a). EPA (1998), recommends an ABS of 0.13 for all the PAHs, which is adopted and used herein. PC and T values are estimated as follows:

P:\1USKZ\HUMANVGUAM\GUAM2\ATTACH2. WPO. 7/77/S90« P") Chemical PC t (cm/hour) (hours) Anthracene 2.25E-1' 1.07E+0* Benzo(a)anthracene 8.1E-lb 2.23E+Ob Benzo(a)pyrene 1.2E+Ob 2.9E+Ob Benzo(b)fluoranthene 1.2E+Ob 3.0E+0" Benzo(k)fluoranthene l.llE+01 3.03E+0* Chrysene 8.1E-lb 2.2E+0" Dibenzo(a,h)anthracene 2.7E+Ob 4.4E+0" Fluoranthene 3.6E-lb 1.5E+0* Indeno(l ,2,3-cd)pyrene 1.9E+0" 4.2E+0" Pyrene 3.24E-1' 1.50E+0* 'Estimated by the method of U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-9 1/01 IB, January. 'Taken from U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-9 1/01 IB, January.

Data regarding the toxicity of acute oral exposure to the PAHs are generally scarce. Prolonged exposure is associated with a number of renal, hematologic and other effects, depending on the compound to which exposed.

A verified RfD of 3E-1 mg/kg-day for chronic oral exposure to anthracene was derived from a NOEL of 1000 mg/kg-day, the highest dose tested, in a 90-day gavage study in mice (EPA, 1999). An uncertainty factor of 3000 was applied. Confidence in the RfD is low. The data are inadequate to identify a target organ for prolonged oral exposure to anthracene.

Subchronic exposure to fluoranthene induces liver and kidney effects in orally treated mice (EPA, 1999). A verified RfD of 4E-2 mg/kg-day for chronic oral exposure was derived from a NOAEL of 125 mg/kg-day in a 13-week gavage study. The LOAEL was 250 mg/kg-day in this study. An uncertainty factor of 3000 was applied. Confidence in the oral RfD is low. The kidney and liver are chosen as the target organs for prolonged oral exposure to fluoranthene.

Subchronic exposure to pyrene induces mild renal tubular degeneration and reduced kidney weight in orally treated mice (EPA, 1999). A verified RfD of 3E-2 mg/kg-day for chronic oral exposure was derived from a NOAEL of 75 mg/kg-day in a 13-week gavage study. The

P:\lUSK3VHUMANVrjUAM\CUAM3\ATrACK2.WPD, 7/Z7A9&06 pn) LOAEL was 125 mg/kg-day in this study. An uncertainty factor of 3000 was applied. Confidence in the oral RfD is low. The kidney is chosen as the target organ for chronic oral exposure to pyrene.

Acenaphthylene, anthracene, benzo(g,h,i)perylene, fluoranthene, fluorene, phenanthrene and pyrene are classified in EPA cancer weight-of-evidence Group D (not classifiable as to carcinogenicity to humans) because of a lack of human data and inadequate animal data (EPA, 1999). Data regarding the carcinogenicity of acenaphthene were not located.

Benzo(a)anthracene, bejpola^pylelbl, benzo(b)fiuoranthene, benzo(k)fluoranthene, carbazole, chrysene, dibenzo(a,h)anthracene, and indeno(l,2,3-cd)pyrene are classified in EPA weight- of-evidence Group B2 (probable human carcinogens) (EPA, 1999, 1997). Benzo(a)pyrene is the most extensively studied member of the class, inducing tumors in tissues at the point of contact of virtually all laboratory species tested by all routes of exposure. Although epidemiology studies suggested that complex mixtures that contain PAHs (coal tar, soots, coke oven emissions, cigarette smoke) are carcinogenic to humans, the carcinogenicity cannot be attributed to PAHs alone because of the presence of other potentially carcinogenic substances in these mixtures (ATSDR, 1993a). In addition, recent investigations showed that the PAH fraction of roofing tar, cigarette smoke and coke oven emissions accounted for only 0.1-8% of the total mutagenic activity in Salmonella of the unfractionated complex mixture (Lewtas, 1988). Aromatic amines, nitrogen heterocyclic compounds, highly oxygenated quinones, diones, and nitrooxygenated compounds, none of which would be expected to arise from in vivo metabolism of PAHs, probably accounts for the majority of the mutagenicity of coke oven emissions and cigarette smoke. Furthermore, coal tar, which contains a mixture of many PAHs, has a long history of use in the clinical treatment of a variety of skin disorders in humans (ATSDR, 1993a).

Because of the lack of human cancer data, assignment of individual PAHs to EPA cancer weight-of-evidence groups is based largely on the results of animal studies with large doses of purified compound (EPA, 1999). Frequently, unnatural routes of exposure, including implants of the test chemical in beeswax and trioctanoin in the lungs of female rats, intratracheal instillation, and subcutaneous or intraperitoneal injection, were used.

EPA (1999) verified a SF for oral exposure to benzo(a)pyrene of 7.3E+0 per mg/kg-day, based on several dietary studies in mice and rats. Recent reevaluations of the carcinogenicity and mutagenicity of the Group B2 PAHs suggest that there are large differences between individual PAHs in cancer potency (Rrewski et al., 1989). Based on the available cancer and mutagenicity data, and assuming that there is a constant relative potency between different carcinogens across different bioassay systems and that the PAHs under consideration have similar dose-response curves, EPA (1993b) adopted relative potency values for several PAHs. These values and the corresponding oral SFs, based on a relative potency for benzo(a)pyrene of 1.0, are presented below.

F-«JSK2\HUMA>l\GUAMVaUAM2\ATTACH2 WPD, 7/T7/9S0-W pm) Relative Potencies and Slope Factors for PAHs PAH Relative Oral Slope Factor Inhalation Potency (/mg/kg-day) Unit Risk Slope Factor (/Mg/m3) (/mg/kg-day) Benzo[aTpyrerie $;0 T.3BHH9 £8B3 3.IBHPO Benzo[a]anthracene 0.1 7.3E-1 8.8E-5 3.1E-1 Benzo[b]fluoranthene 0.1 7.3E-1 8.8E-5 3.1E-1 Benzo[k]fluoranthene 0.01 7.3E-2 8.8E-6 3.1E-2 Chrysene 0.001 7.3E-3 8.8E-7 3.1E-3 Dibenzo[a,h]anthracene 1.0 7.3E+0 8.8E-4 3.1E+0 Tndennf 1 ,2 ^-r,d"|pyrenft 0 1 7 ^F.-1 8 8F-

Although the EPA has not verified SFs for Group B2 PAHs other than benzo(a)pyrene, the SFs above represent reasonable estimates based on the data available. The relative potency approach employed here meets criteria considered to be desirable for this type of analysis (Lewtas, 1988). For example, the chemicals compared have similar chemical structures and would be expected to have similar toxicokinetic fate in mammalian systems. In addition, the available data suggest that the Group B2 PAHs have a similar mechanism of action, inducing frameshift mutations in Salmonella and tumor initiation in the mouse skin painting assay. Similar noncancer effects (minor changes in the blood, liver, kidneys) of the Group D PAHs support the hypothesis of a common mechanism of toxicity. Finally, the same endpoints of toxicity, i.e., potency in various cancer assays, and related data, were used to derive the relative potency values (Krewski et al., 1989). The oral SF for benzo(a)pyrene of 7.3E+0 per mg/kg-day, and the SFs presented above for the other Group B2 PAHs are adopted for the purposes of this evaluation.

A recent EPA (1994) evaluation of the inhalation cancer data suggests adoption of an inhalation SF for benzo(a)pyrene of 3.1E+0 per mg/kg-day, based on the incidence of upper respiratory and digestive tract tumors in hamsters. Applying the relative potency estimates presented above yield the inhalation SFs for the other Group B2 PAHs presented above.

I^V]USia\HUMAKVCUAMV3UAMZVATTACH2.WFO. 7/77/990-M pm) References for PATfg

Agency for Toxic Substances and Disease Registry, (ATSDR), 1993a, Update Toxicological Profile for Polycyclic Aromatic Hydrocarbons (PAHs), Draft for Public Comment, U.S. Public Health Service, Atlanta, Georgia, October.

Agency for Toxic Substances and Disease Registry, (ATSDR), 1993b, Update Toxicological Profile for Naphthalene, Draft for Public Comment, U.S. Public Health Service, Atlanta, Georgia, October.

Jones, TD. and BA Owen, 1989, Health Risks from Mixtures of RadionucUdes and Chemicals in Drinking Water, Oak Ridge National Laboratory, Oak Ridge, TN, ORNL-6533.

Krewski, D., T. Thorslund and J. Withey, 1989, "Carcinogenic Risk Assessment of Complex Mixtures," Toxicology and Industrial Health, 5: 851-867.

Lewtas, J., 1988, "Genotoxicity of Complex Mixtures: Strategies for the Identification and Comparative Assessment of Airborne Mutagens and Carcinogens from Combustion Sources," Fundamental and Applied Toxicology, 10: 571-589.

U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, January.

U.S. Environmental Protection Agency (EPA), 1993 a, Risk Assessment Issue Paper for: Derivation of a Subchronic RfC for Naphthalene (CASRN 91-20-3), National Center for Environmental Assessment, Cincinnati, Ohio, March 12.

U.S. Environmental Protection Agency (EPA), 1993b, Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons, Office of Health and Environmental Assessment, Cincinnati, OH, EPA/600/R-93/089.

U.S. Environmental Protection Agency (EPA), 1994, Risk Assessment Issue Paper: Status of Inhalation Cancer Unit Risk for Benzo(a)Pyrene (CAS No. 50-32-8), National Center for Environmental Assessment, Cincinnati, OH, November 18.

U.S. Environmental Protection Agency (EPA), 1997, Health Effects Assessment Summary Tables, FT1997 Update, Office of Solid Waste and Emergency Response, Washington, DC, 9200.6-303(97-1), EPA 540/R-97-036, PB97-921199.

U.S. Environmental Protection Agency (EPA), 1998, Region 9 Preliminary Remediation Goals (PRGs) 1998, online, http://www.epa.gov/region 09/.

U.S. Environmental Protection Agency (EPA), 1999, Integrated Risk Information System (IRIS), National Center for Environmental Assessment, Cincinnati, OH, on line.

P-\RJSK2OTAlAN\OTAM\GUAMriMTACH2 WPC. 7/77/99(3 IX pm) POLYCHLORINATHD DTBENZO--DIOXTNS rPCDDI AND DIBEN7,OFTJRANS

The PCDD/PCDF are a class of SVOCs including 15 possible positional congeners of PCDD and 135 possible positional congeners of PCDF (EPA, 1994). PCDD/PCDF are not commercially produced in the U.S.; they are produced as undesirable by-products during the manufacture of chlorinated phenolic compounds for which 2,4,5-trichlorophenol is a synthetic intermediate (ATSDR, 1989). The predominant source of PCDD/PCDF release to the environment is emissions from incinerators (EPA, 1994).

The development of toxicity equivalency factors (TEF) to facilitate evaluation of exposure to the PCDD/PCDF (see below) has encouraged refinement of the analytical techniques for these compounds in environmental media, because it is assumed that only those homologues with chlorine substituents in the 2,3,7,8-positions (including 7 PCDD and 10 PCDF congeners) exhibit significant toxicity. Whereas formerly PCDD/PCDF analysis yielded estimates of specific homologues (PCDD or PCDF with the same number of chlorine substituents, regardless of their spatial arrangement), modern analysis identifies individual congeners, or at least homologues with chlorine substituents at the 2,3,7,8-positions. The toxicologically significant PCDD/PCDF may be evaluated individually or may be evaluated by converting their concentrations to equivalent concentrations of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), or TCDD equivalents (TEQ), which are summed to yield total TEQ. Physical constants are not available for all the toxicologically significant PCDD/PCDF congeners; therefore, the physical constants for 2,3,7,8- TCDD are usually applied to the individual congeners or to the TEQ. Relevant physical properties of 2,3,7,8-TCDD are compiled below:

MW logK^ H logK« D. Dw VP S (g/mole) (unitless) (atm-mVmole) (unitless) (cmVs) (cmVs) (atm) (mg/L) 322.0 6.80* 5.4E-23k 6.6b ND 4.9E-6b 8.4E-13b 3.2E-4k ND = no data. *U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-9 1/01 IB, January. 'Montgomery, J.H., 1996, Groundwater Chemicals Desk Reference, Second Edition, Lewis Publishers, New York.

Data were not located regarding the toxicokinetics of all the PCDD/PCDF that may be identified in environmental media; however, TCDD is used as a surrogate for other members of these chemical classes. Estimates of the Gl absorption of TCDD range from 50 to 86% of the administered dose in rats; comparable data were obtained for hamsters (EPA, 1985, ATSDR, 1989). The efficiency of absorption is greater when the test material is given in a corn oil vehicle (70-86%) than when it is incorporated in the diet (50-60%) or soil (quantification not provided) (EPA, 1985). An approximate GAF of 0.9 is adopted for this evaluation. Dermal absorption of TCDD in methanol by rats after 24 hours approximated 40% of that absorbed by the Gl tract after an equivalent dose in ethanol (EPA, 1985). EPA (1998) recommends an ABS of 0.03 for TCDD, which is used herein. EPA (1992) provides a PC of 1.4E-K3 cm/hour and a T of 8.1E+0 hours.

P'ViUSK2\HUMANVCUAMVGUAMZVATTACH2.'WFO. 7/77/99(3-06 pra) 10 The PCDD/PCDF are among the compounds that bio accumulate in food chain pathways and are of special concern for biomagnification from sediment in benthic fish. EPA (1995b) reported log and BSAF values for the PCDD/PCDF as follows:

PCDD/PCDF Congener logK™ BSAF Value 2,3,7,8-TCDD 7.02" 0.059 1 ,2,3,7, 8-PeCDD 7.50 0.054 1,2,3,4,7,8-HxCDD 7.80 0.018 1,2,3,6,7,8-HxCDD 7.80 0.0073 1,2,3,7,8,9-HxCDD 7.80 0.0081 1,2,3,4,6,7,8-HpCDD 8.20 0.0031 OCDD 8.60 0.00074 2,3,7,8-TCDF 6.5 0.047 1,2,3,7,8-PeCDF 7.0 0.013 2,3,4,7,8-PeCDF 7.0 0.095 1,2,3,4,7,8-HxCDF 7.5 0.0045 1,2,3,6,7,8-HxCDF 7.5 0.011 2,3,4,6,7,8-HxCDF 7.5 0.040 1,2,3,7,8,9-HxCDF 7.5 0.037 1,2,3,4,6,7,8-HpCDF 8.0 0.00065 1,2,3,4,7,8,9-HpCDF 8.0 0.023 OCDF 8.80 0.001 "Note that this value differs slightly from that provided by U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, January.

TCDD = tetrachlorodibenzo-p-dioxin, PeCDD = pentachlorodibenzo-p-dioxin, HxCDD = hexachlorodibenzo-p-dioxin, HpCDD = heptachlorodibenzo-p-dioxin, OCDD = octachlorodibenzo-p-dioxin, TCDF = tetrachlorodibenzofuran, PeCDF = pentachlorodibenzofuran, HxCDF = hexachlorodibenzofuran, HpCDF = heptachlorodibenzofuran, OCDF = octachlorodibenzofuran.

The BSAF values may be applied to the individual PCDD/PCDF congeners to derive a "BSAF' that is applied to the total TEQ.

P:\XISK2\HUMAN\GUAM\CRJAM2\ATTACTO.WPD, 7/37/99(3:06 pm) 11 The only effect in humans clearly attributable to TCDD is chloracne (ATSDR, 1989). The epidemiological data, however, also associate exposure to TCDD with hepatotoxicity and neurotoxicity, although the association is not strong. In animals, toxicity of TCDD is most commonly manifested as a wasting syndrome with thymic atrophy terminating in death, with a large number of organ systems showing non-specific effects. Chronic treatment of animals with TCDD or a mixture of two isomers of hexachlorodibenzo-p-dioxin results in liver damage. Immunologic effects may be among the more sensitive endpoints of exposure to the PCDDs in animals. TCDD is a developmental and reproductive toxicant in animals. Data were not located regarding the noncancer toxicity of the other PCDDs or PCDFs. No verified or provisional noncancer toxicity values were located for any of the PCDD/PCDF.

Data regarding the carcinogenicity of TCDD to humans, obtained from epidemiologic studies of workers exposed to pesticides or to other chlorinated chemicals known to be contaminated with TCDD, are conflicting (ATSDR, 1989). The interpretation of these studies is clouded because exposure to TCDD was not quantified, multiple routes of exposure (dermal, inhalation, oral) were involved, and the workers were exposed to other potentially carcinogenic compounds. TCDD, however, is clearly carcinogenic in animals, inducing thyroid, lung and liver tumors in orally treated rats and mice (EPA, 1985). Similarly, oral treatment with a mixture of two hexachlorodibenzo-p-dioxin isomers induces liver tumors hi rats and mice. On the basis of the animal data, TCDD and the hexachlorodibenzo-p-dioxins were assigned to EPA cancer weight-of- evidence Group B2 (probable human carcinogen). All the PCDD/PCDFs are treated as probable human carcinogens.

EPA (1997) presents provisional oral and inhalation SFs for TCDD of 1.5E+5 per mg/kg-day, based on the incidence of liver and lung tumors in an oral study in rats. The inhalation SF, however, is adjusted to 1. 1E+5 per mg/kg-day to account for route-specific differences in absorption. In the absence of satisfactory congener-specific cancer data, EPA (1989) derived TEFs for the other PCDDs and PCDFs, by assuming that all manifestations of toxicity of all members of these classes are mediated by a common mechanism, i.e., binding to the intracellular AH receptor of target cells. Applying the TEFs to the SF for TCDD, SFs are estimated for the other PCDD/PCDF as follows:

OralSF Inhalation SF Compound TEF (per mg/kg-day) (per mg/kg-day) Mono-, di- and tri-CDD 0 NA NA 2,3,7,8-TCDD 1 1.5E+5 l.lE-f-5 Other TCDD 0 NA NA 2,3,7,8-PeCDD 0.5 7.5E+4 5.5E+4 Other PeCDD 0 NA NA 2,3,7,8-HxCDD 0.1 1.5E+4 1.1E+4 Other HxCDD 0 NA NA

^\}USK2VHUMAN\GUAM\CUAMftATrACHrWPD. 7/77/99(3-06 pm) 12 OralSF Inhalation SF Compound TEF (per mg/kg-day) (per mg/kg-day) ' 2,3,7,8-HpCDD 0.01 1.5E+3 llE-r-3 OCDD 0.001 L 1.5E+2 1.1E+2 Mono-, di- and tri-CDF 0 NA NA 2,3,7,8-TCDF 0.1 1.5E+4 1.1E+4 Other TCDF 0 NA NA 1,2,3,7,8-PeCDF 0.05 7.5E+3 5.5E+3 2,3,4,7,8-PeCDF 0.5 7.5E+4 5.5E+4 Other PeCDF 0 NA NA 2,3,7,8-HxCDF 0.1 1.5E+4 1.1E+4 Other HxCDF 0 NA NA 2,3,7,8-HpCDF 0.01 1.5E+3 1.1E+3 Other HpCDF 0 NA NA OCDF 0.001 1.5E+2 1.1E+2 TEF = toxicity equivalency factor, SF = slope factor, CDD = chlorinated dibenzo-p-dioxin, NA = not applicable, TCDD = tetrachlorodibenzo-p-dioxin, PeCDD == pentachlorodibenzo-p- dioxin, HxCDD = hexachlorodibenzo-p-dioxin, HpCDDs = heptachlorodibenzo-p-dioxin, OCDD = octachlorodibenzo-p-dioxin, TCDF = tetrachlorodibenzofuran, PeCDF = pentachlorodibenzofuran, HxCDF = hexachlorodibenzofuran, HpCDF = heptachlorodibenzofuran, OCDF = octachlorodibenzofuran

The TEFs were derived not from cancer data, but from in YiLTO. data such as enzyme induction, which is hypothetically related to the carcinogenic mode of action. For example, the TEF of 0.001 for OCDD and OCDF is based on the appearance of "dioxin-like" effects and detectable levels of OCDD late in a 13-week study in male rats treated with OCDD, and on in yi evidence of enzyme induction (EPA, 1989).

13 References for PCDD/PfDF

Agency for Toxic Substances and Disease Registry, (ATSDR), 1989, Toxicological Profile for 2,3,7,8-Tetrachloro-dibenzo-p-dioxin, U.S. Public Health Service, Atlanta, Georgia.

U.S. Environmental Protection Agency (EPA), 1985, Health Assessment Document for Polychlorinated Dibenzo-p-Dioxins, Office of Health and Environmental Assessment, Washington, DC, EPA/600/8-84/014F, NTIS No. PB86-122546.

U.S. Environmental Protection Agency (EPA), 1989, Interim Procedures for Estimating Risks Associated with Exposures to Mixtures of Chlorinated Dibenzo-p-Dioxins and - Dibenzofurans (CDDs and CDFs) and 1989 Update, Prepared by the Risk Assessment Forum for the Office of Health and Environmental Assessment, Washington, DC, EPA/625/3-89/016, NTIS PB90-145756/AS.

U.S. Environmental Protection Agency (EPA), 1994, Estimating Exposure to Dioxin-Like Compounds, Review draft, June, EPA/600/6-88/005Ca.

U.S. Environmental Protection Agency (EPA), 1995a, Supplemental Guidance to RAGS: Region 4 Bulletins, Human Health Risk Assessment (Interim), Waste Management Division, Office of Health Assessment, EPA Region 4, Atlanta, GA, November.

U.S. Environmental Protection Agency (EPA), 1995b, Great Lakes Water Quality Initiative, Technical Support Document for the Procedure to Determine Bioaccumulation Factors, EPA.820.8.95.CC5, PB95-187290.

U.S. Environmental Protection Agency (EPA), 1997, Health Effects Assessment Summary Tables, FY1997 Update, Office of Solid Waste and Emergency Response, 9200.6-303 (97-1), EPA-540-R-97-036, NTIS No. PB97-921199.

U.S. Environmental Protection Agency (EPA), 1998, Region 9 Preliminary Remediation Goals (PRGs) 1998, online, http://www.epa.gov/region 09A

P \JUSK2\HUMAJW3UAMvGUAM3\ATTACH2 WPD, 7/77/99(3-06 pm) 14 POLYCHLORJNA' .5? flPCBsl

The PCBs are a class of SVOCs including 209 possible individual congeners, each consisting of a biphenyl structure and 1 to 10 chlorine atoms (ATSDR, 1995). The PCBs manufactured and used in the U.S. are called Aroclors. The Aroclors are mixtures of several PCB congeners and related compounds. Aroclors were used as dielectric and heat exchange agents in several open and closed systems, but since the middle 1970s, use has been restricted largely to electrical transformers and capacitors.

Analysis of PCBs in environmental media frequently involves "fingerprinting" the mixture, and reporting the result as the Aroclor(s) that most closely reflect the fingerprint(s) (ATSDR, 1995). Recently, however, more attention has been paid to analyzing and reporting individual congeners, because of the possibility that certain congeners may be dioxin-like in their action of toxicity. The Aroclors most commonly identified in environmental media include Aroclor-1016, -1221, -1232, -1242, -1248, -1254, -1260, -1262, and -1268. Relevant physical properties are compiled below:

MW H W S fatm-m /Tnnlel (cm*/s) (atm) (mg/L) Aroclor-1016 257.9*,), 5.6b 2.9E-4b 4.96c ND 68£-6c r 5.3E-7b 4 2E, Aroclor-1221 200.7.J, 3.5E-3b 2.44c ND 7.5E-6c 8.8E-6b Aroclor-1232 232.2.,b I 5" I 8.64E-4c I 283- 1 ND I 7.2E-6c I 5.34E-6b Aroclor-1242 266.5.,b 5.6b I 5.:.2E-4b IJfLJL ND 6.1E-6c I 5.34-7b j 22E-1" 62 Aroclor-1248 299.5.J, \ > r 2.8E-3i 5.64c ND ]|6^E-6. I 6.5E-7b J17E-2'' Aroclor-1254 328».b 6.5b 5.00. ND 5.6E-6cj 1.01E-7bj 35E-2b Aroclor-1260 37S.7.A 6.8b 4.6E-3b 6.42c ND 5.3E-6c 5.33E-8b Aroclor-1262 r^^^ ND ND Aroclor-1268 453».b i N° r ND ND J NP |, 1NP I 3.0E-1" ND = no data. •Average molecular mass for the proportions of individual congeners in the commercial product. bAgency for Toxic Substances and Disease Registry (ATSDR), 1995, Update Toxicological Profile f or Polychorinted Biphenyls, Draft for Public Comment, U.S. Department of Health and Human Services, Atlanta, Georgia, August. ^Montgomery, J.H., 1996, Groundwater Chemicals Desk Reference, Second Edition, Lewis Publishers, New York.

P \WSW\HUMAIW3UAM\GUAMIUUTACH2 WPD. 7/27/»

Toxicokinetic data from laboratory animals suggests that the efficiency of Gl absorption is roughly inversely related to the degree of chlorination (ATSDR, 1995). The Gl absorption of mono-to hexachlorinated biphenyls exceeds 90 percent. Dichlorobiphenyl Gl absorption efficiency is approximately 95 percent, but the absorption efficiency of octachlorobiphenyl approximates only 75 percent. Gl absorption efficiency of Aroclor-1254 approximates 85.4 percent in ferrets and greater than 90 percent in monkeys. These data generally support the GAF of 0.9, which is adopted for all PCBs in this evaluation. However, an oral-to-dermal absorption factor of 1 is used for the cancer evaluation to be consistent with the application of the cancer SF recommended by EPA (1999).

The PCBs appear to be readily absorbed by the skin when applied as neat compound or mixed with a suitable vehicle (ATSDR, 1995), but efficiency falls off when soil is the medium of exchange. The EPA (1992) recommended ABS of 0.06 for PCBs is used in this evaluation. EPA (1992) provides PC and t values for 4-chlorobiphenyl and hexachlorobiphenyl. Generally, the more highly chlorinated PCB congeners are the more persistent in the environment; therefore, the PC of 7.1E-1 cm/hour and the T of 1.4E+1 hours for hexachlorobiphenyl are applied to all PCBs in this evaluation.

The acute oral toxicity of the PCBs is low to moderate, as indicated by LD^ values in laboratory animals ranging from 750 mg/kg (mink) to 4250 mg/kg (rats) (ATSDR, 1993). Death appears to be due to respiratory depression and dehydration from diarrhea.

The best known incident involving oral exposure by humans is the "Yusho" incident in Japan, in which persistent chloracne, gastrointestinal irritation and central nervous symptoms followed ingestion of cooking oil contaminated with PCBs (Gaffey, 1983). Further investigation, however, revealed that concentrations of polychlorinated dibenzofurans (PCDF) and polychlorinated quaterphenyls in the cooking oil were similar to those of PCBs, which confounds the interpretation of the results of this study.

Prolonged oral exposure of laboratory animals leads to liver damage, signs of chloracne, immunological effects, and neurological impairment, particularly of the young. A verified oral RfD for Aroclor-1254 of 2E-5 mg/kg-day for chronic oral exposure is based on a LOAEL of 5E-3 mg/kg-day associated with chloracne and related signs and immunological effects in monkeys treated with the test material in gelatin capsules for over five years (EPA, 1999). An uncertainty factor of 300 was applied. Confidence in the RfD is medium. The immune system and skin are considered the target organs for prolonged oral exposure to Aroclor-1254. A verified oral RfD of 7E-5 mg/kg-day for Aroclor-1016 is based on a NOAEL of 7E-3 mg/kg-day in a long-term perinatal and neurobehavioral toxicity study in monkeys. An uncertainty factor of 100 was applied to the NOAEL. The LOAEL (2.8E-2 mg/kg-day) was associated with low birth

P:\WSKTJRJMAN\GUAM1GUAMTATTACH2.WPD, 7/27/S9CUK pa) 16 weights. The fetus is considered the sensitive target tissue for prolonged oral exposure to Aroclor-1016. Confidence in the oral RfD is medium.

Occupational exposure to PCBs, which involved both inhalation and dermal exposure, was associated with upper respiratory tract and ocular irritation, loss of appetite, liver enlargement and increased serum concentrations of liver enzymes, skin irritation, rashes and chloracne, and, in heavily exposed female workers, decreased birth weight of their infants (ATSDR, 1995). Concurrent exposure to PCB contaminants, such as PCDFs, confound the interpretation of the occupational exposure studies. Rats, mice, rabbits and guinea pigs intermittently exposed to Aroclor-1254 vapors exhibit moderate liver degeneration, decreased body weight gain and slight renal tubular degeneration; however, the accuracy of the reported exposure concentration is in doubt. Neither verified nor provisional chronic inhalation RfC values are available.

EPA (1999) classified PCBs in cancer weight-of-evidence Group B2 (probable human carcinogen) based on adequate evidence for liver tumors in laboratory animals and inadequate data in humans. EPA (1999) established a tiered approach for estimating the cancer potency of exposure to the PCBs. For the high risk tier, A SF of 2.0E+0 per mg/kg-day is verified as an upper-bound for exposure to PCBs via ingestion in the food chain, ingestion of soil or sediment, inhalation of dust or aerosol, or dermal contact with soil or sediment if an absorption factor is applied. In addition, the SF of 2.0E+0 per mg/kg-day is used for any congeners considered to be persistent or acting in a dioxin-like manner, and for any early life exposures. The high risk tier SF for central tendency (CT) analyses is l.OE+0 per mg/kg-day. EPA (1999) verified an upper-bound SF of 4.0E-1 per mg/kg-day for the low risk tier, which includes ingestion of water-soluble congeners, inhalation of evaporated congeners, and dermal exposure if no absorption factor is applied. A SF of 3E-1 per mg/kg-day is recommended for the low risk CT evaluation. The SF of 2.0E-K) per mg/kg-day is used for all exposure scenarios and exposure routes in this evaluation because analytical data that demonstrate the absence of dioxin-like or persistent congeners are not available, and the exposure of children or youths is plausible.

References for PCBs

Agency for Toxic Substances and Disease Registry, (ATSDR), 1995, Update Toxicological Profile for Polychlorinated Biphenyls, Draft for Public Comment, U.S. Public Health Service, Atlanta, Georgia, August.

Gaffey, W.R., 1983, "The epidemiology of PCBs," In: PCBs: Human and Environmental Hazards, F.M. D'itri and M.A. Kamrin, Eds., Boston: Butterworth Publishers.

U.S. Environmental Protection Agency (EPA), 1992, Dermal Exposure Assessment: Principles and Applications, Interim Report, Office of Research and Development, Washington, DC, EPA/600/8-91/01 IB, January.

U.S. Environmental Protection Agency (EPA), 1995, Great Lakes Water Quality Initiative, Technical Support Document for the Procedure to Determine Bioaccumulation Factors, EPA.820.8.95.CC5, PB95-187290.

P \RJSK2\HUMAfAGUAMV3UAM2\ATTACH2 WPD. 7/27/990-06 pm) 17 U.S. Environmental Protection Agency (EPA), 1999, Integrated Risk Information System (IRIS), National Center for Environmental Assessment, Cincinnati, OH, on line.

18 FINAL SCREENING ECOLOGICAL RISK ASSESSMENT FOR IRP SITE 39/HARMON SUBSTATION ANDERSEN AIR FORCE BASE GUAM

Prepared for:

United States Air Force Andersen Air Force Base Guam

Prepared by:

IT Corporation 5301 Central Avenue NE, Suite 700 Albuquerque, New Mexico 87108

July 1999 Executive Summary. This screening level ecological risk assessment has been prepared in support of the U.S. Air Force Installation Restoration Program. The scope of work for this project includes an evaluation of potential risks to biota that may presently or in the future utilize IRP Site 39/Harmon Substation, Harmon Annexes, Andersen Air Force Base, Guam. This document is in support of the Remediation Verification Report for the site.

This risk assessment was performed in accordance with federal and regional EPA guidance on ecological risk assessment (EPA, 1992; EPA, 1997; EPA, 1998a; Callahan, 1998). Both conservative and realistic assumptions were used in the evaluation of potential risk to biota that may use the site either at present or in the future. Ecological receptors selected for analysis were a generic plant, insectivorous small mammal, omnivorous small mammal, predatory mammal, insectivorous bird, and a predatory reptile. Emphasis in this assessment was on the protection of upper trophic level receptors.

The results of this screening level risk assessment indicate no inorganics, volatile organic compounds, polycyclic aromatic hydrocarbons (PAH), or polychlorinated biphenyls (PCB) present significant risk to terrestrial receptors at this site. Potential risks to insectivorous birds from exposures to 4,4'-DDE and 4,4'-DDT were initially identified under the most conservative modeling conditions; however, the evaluation of uncertainties associated with these predictions makes such predictions of risk dubious and the actual risk is probably negligible. The screening level assessment initially identified potential risk to all wildlife receptors from exposures to dioxins and furans. Factors associated with uncertainties and ecological significance support the conclusions that these risk predictions for the insectivorous bird and predatory mammal (and thereby indirectly predicted for the predatory reptile) are overestimations and that the actual risks to these receptors are negligible. The same is probably also true for the omnivorous small mammal. However, the predicted risk to the insectivorous small mammal was relatively high, and if this taxa is present on the site, it may be adversely affected by exposure to dioxins and furans. Because the site is small, highly disturbed, and is not located in important natural habitat, and because neither of the small mammal receptors represent ecologically significant or protected species, it is concluded that the overall ecological risks at this site are negligible and that there is adequate information to conclude that no further investigation or remediation are required.

AU7-99/WP/AnderseirEco-risk_AppM_AgencyDraft.DOC : 919689 21 00 60 30 7/28/99 5.02 PM Table of Contents

Executive Summary i List of Tables iv List of Figures v List of Abbreviations/Acronyms vi 1.0 Introduction 1-1 2.0 Problem Formulation 2-1 2.1 Physical Setting 2-1 2.1.1 Climate 2-1 2.1.2 Geology 2-3 2.1.3 Topography and Surface Water 2-4 2.1.4 Soil 2-4 2.1.5 Groundwater 2-4 2.1.6 Land use 2-5 2.2 Ecological Setting 2-5 2.3 Site History 2-6 2.3.1 1989 POL Excavation 2-6 2.3.2 1997 Investigation 2-6 2.3.3 Post-1997 Excavation and Sampling History 2-10 2.3.4 Data Validation 2-13 2.4 Constituents of Potential Ecological Concern 2-14 2.5 Fate and Transport Potential 2-17 2.6 Ecological Receptors 2-17 2.7 Exposure Pathways 2-23 2.8 Ecological Endpoints 2-25 3.0 . Analysis 3-1 3.1 Exposure Characterization 3-1 3.2 Ecological Effects Evaluation 3-4 3.2.1 Plant Toxicity Reference Values 3-6 3.2.2 Wildlife Toxicity Reference Values 3-7 3.2.3 Reptilian Toxicity Data 3-10 4.0 Risk Characterization 4-1 4.1 Risk Estimation 4-1 4.2 Risk Results ...... 4-2

AI77-99/WP/Andersen.Eco-nsk_AppM_AgencyDraft DOC jj 919689.21.00.60 30 7/28/99 5:02 PM Table of Contents (Continued).

4.3 Uncertainty Analysis 4-6 4.4 Ecological Significance 4-9 4.5 Scientific/Management Decision Point 4-10 5.0 Summary 5-1 6.0 References 6-1

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgcncyDraft.DOC jjj 919689.21.00.60.30 7/28/99 5:02 PM List of Tables

Table Title

1 List of Federal and Guam Endangered Species Found on Andersen Air Force Base

2 Summary of Excavation and Sampling Activities at IRP Site 39/Harmon Substation, 1998

3 Soil Sampling Results and Exposure Point Concentrations for Constituents of Potential Ecological Concern Andersen Air Force Base, Guam

4 Ecological Endpoints IRP Site 39/Harmon Substation, Andersen Air Force Base, Guam

5 Exposure Factors for Ecological Receptors IRP Site 39/Harmon Substation, Andersen Air Force Base, Guam

6 Transfer Factors for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

7 Nonlinear Model Parameters for Modeling Constituents of Potential Ecological Concern in Earthworm and Mammal Tissues Andersen Air Force Base, Guam

8 Toxicity Benchmark Information for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

9 TCDD Toxicity Equivalency Factors for the Birds and Mammals

10 Hazard Quotients Based on Exposures to Maximum Measured Soil Concentrations for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

11 Hazard Quotients Based on Exposures to 95-Percent Upper Confidence Limit Soil Concentrations for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

12 Comparison of Exposures in the Mangrove Monitor Lizard to Those in the Feral Dog and Micronesian Starling for Constituents of Potential Ecological Concern, IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC jy 919689.21.00.60.30 7/28/99 5:02 PM List of Figures.

Figure Title

1 Ecological Risk Assessment Approach for IRP Site 39/Harmon Substation in Comparison with the U.S. Environmental Protection Agency's Approach for Superfund Sites, Andersen Air Force Base, Guam

2 Location Map, IRP Site 39/Harmon Substation, Harmon Annexes, Andersen Air Force Base, Guam

3 Conceptual Model for Terrestrial Habitat of IRP Site 39/Harrnon Substation, Andersen Air Force Base, Guam

4 Generalized Food Web for the Terrestrial Habitat at IRP Site 39/Harmon Substation, Andersen Air Force Base, Guam

AL/7-99/WP/Andersen.Eco-nsk_AppM_AgencyDraft.DOC v 919689.21.00.60.30 7/28/99 5 02 PM List of Abbreviations/Acronyms.

AFB Air Force Base bgs below ground surface BHC benzene hexachloride BTV background threshold value COPEC constituent of potential ecological concern d day DDD 1,1 -dichloro-2,2-bis(p-chlorophenyl)ethane DDE 1,1 -dichloro-2,2-bis(p-chlorophenyl)ethylene DDT 1,1,1 -trichloro-2,2-bis(p-chlorophenyl)ethane Dept. Department EPA Unites States Environmental Protection Agency F Fahrenheit ft. feet HpCDD heptachlorodibenzo-p-dioxin HpCDF heptachlorodibenzofuran HQ hazard quotient HxCDD hexachlorodibenzo-p-dioxin HxCDF hexachlorodibenzofuran in. inch(es) IRP Installation Restoration Program Kow octanol/water partition coefficient kg kilogram(s) km kilometer LOAEL lowest-observed-adverse-effect level log logarithm m meter(s) MCL maximum concentration level mg milligram(s) mph miles per hour NOAEL no-observed-adverse-effect level OCDD octachlorodibenzo-p-dioxin OCDF octachlorodibenzofuran PAH polycyclic aromatic hydrocarbon PCB polychlorinated biphenyl PCDD polychlorinated dibenzo-p-dioxin PCDF polychlorinated dibenzofuran PeCDD pentachlorodibenzo-p-dioxin PeCDF pentachlorodibenzofuran POL petroleum, oils, and lubricants PRG preliminary remediation goal SVOC Semivolatile organic compound TCDD tetrachlorodibenzo-p-dioxin TCDF tetrachlorodibenzofuran

ALy7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC VI 919689.21 00.60.307/28/995:02 PM List of Abbreviations/Acronyms (Continued).

TEF toxicity equivalency factor TEQ toxicity equivalency TPH total petroleum hydrocarbon UCL upper confidence limit USFWS United States Fish and Wildlife Service VOC volatile organic compound WHO World Health Organization 0 degree

AL77-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC y j j 919689.21.00.60.30 7/28/99 5:02 PM 1.0 Introduction

This screening level ecological risk assessment was performed to address the potential impact on biota from exposure to chemical contaminants associated with Installation Restoration Program (IRP) Site 39/Harmon Substation, located in the Harmon Annexes, Andersen Air Force Base (AJFB), Guam. This document is in support of the Remediation Verification Report for the site. It specifically addresses potential risks to ecological receptors associated with soils from the site that have recently undergone polycyclic aromatic hydrocarbon (PAH) and polychlorinated biphenyl (PCB) remediation. No assessment has been previously performed to address potential ecological risks at this site. Therefore, the intent of this assessment was to focus on potential risks to biota which may utilize the site either at present or in the future based on soil sampling data collected during and after site remediation. Most species at the site are introduced, non- native species, that infrequently utilize this highly disturbed site. The potential exists, however, for habitat conditions to improve in the future followed by greater utilization by wildlife within the area.

The ecological risk assessment methodology used in this assessment generally follows U.S. Environmental Protection Agency (EPA) ecological risk assessment guidance (EPA, 1992; EPA, 1997; EPA, 1998a) and that recommended by EPA Region 9 (Callahan, 1998). The Guam EPA does not currently have its own ecological risk guidance (Richman, 1999). Both conservative and realistic assumptions were used in the evaluation of potential risk to biota that may use the site either at present or in the future. This assessment contains a Problem Formulation section that provides the introduction to the risk evaluation process. Components addressed within the Problem Formulation section include a discussion of the environmental setting, site history, selection of constituents of potential ecological concern (COPECs), a discussion of fate and transport potential, potential ecological receptors, complete exposure pathways, and assessment and measurement endpoints.

Problem Formulation is followed by the evaluation of exposure, toxicity, and predicted risks. The characterization of exposure and toxicity are components of the Analysis Section of the risk assessment. The Risk Characterization section contains discussions of the uncertainty and ecological significance associated with the assessment of ecological risk for the site. The ecological risk evaluation process concludes with a Scientific/Management Decision Point that provides a recommendation of efforts that should follow this screening level ecological risk assessment. Figure 1 illustrates the ecological risk assessment methodology used in this report

AL/7-99/WP/Andersen:Eco-risk_ AppM_AgencyDraft.DOC j_} 919689.21.00.60.307/28/995:02 PM USEPA Eight-step Ecological Risk Assessment Ecological Risk Assessment Approach Process for Superfund (EPA 1997) for IRP Site 39/Harmon Substation Tier 1: Screening Risk Assessment STEP 1: Screening-Level Problem Formulation and Ecological Ellects Evaluation STEP v Site Visit; Pathway Identification/Problem Formulation; Toxicity Evaluation

STEP 2: Screening-Level Preliminary Exposure Estimate and Risk Calculation STEP 2- Exposure Estimate, Risk Calculation

Does screening-level risk calculation indicate risk or have unacceptable data gaps? screening-level risk calculation Scope o! the current risk assessment for indicate risk? IRP Site 39/Harmon Substation

STEP 3- Baseline Risk .Assessment Problem Formulation

Refinement of Conservative Risk Calculation STEP 3a: Refinement of Conservative Risk Calculation

Does the site pose an unacceptable risk' Conceptual Model Exposure Pathways

Tier 2: Baseline Ecological Risk Assessment

STEP 4: Study Design and Data Quality Objectives (DQOs) - Lines of Evidence - Measurement Endpoints Work Plan and Sampling/Analysis Plan

STEP 5: Verification of Field Sampling Design }~~frf 'MOP (d)

STEP 6: Site Investigation and Analysis of Exposure and Effects

STEP 4: Study Design and Data Quality Objectives (OQOs) STEP 7: Risk Characterization - Lines of Evidence - Measurement Endpoints Work Plan and Sampling/Analysis Plan STEP 8: Risk Management

j STEP 5. Verification of Field Sampling Design Is risk characterization complete with no unacceptable dala gaps?_ STEP 6. Site Investigation and Analysis of Exposure and Effects

-YES—frf SMDP (e)~

Figure 1 Does baseline-level nsk assessment Ecological Risk Assessment Approach 7 indicate unacceptable risk for IRP Site 39/Harmon Substation in Comparison with the U.S. Environmental Protection Agency's Tier 3: Evaluation of Remedial Alternatives Approach for Superfund Sites, - Develop site-specific risk-based cleanup goals - Evaluate remedial alternatives Andersen Air Force Base, Guam

9(968921 006030 81 as it relates to that presented in the Superfund Guidance for Ecological Risk Assessment (EPA, 1997). The scope of this risk assessment is limited to the Tier 1 screening level assessment.

AL/7-99/WP/Andersen Eco-nsk_AppM_AgencyDraft DOC j _3 919689.21 00 60 30 7/28/99 5'02 PM 2.0 Problem Formulation

Problem Formulation is the first step of the ecological risk assessment process. This step includes a discussion of the physical and ecological characteristics of the site, selection of COPECs, potential fate and transport mechanisms, selection of ecological receptors, exposure pathways, and ecologically relevant assessment and measurement endpoints. As discussed in Section 2.8, the overall management goal of ihis assessment is to ensure the integrity of the biological community within the terrestrial habitats of IRP Site 39/Harmori Substation. The Problem Formulation step basically sets the stage for the evaluation of exposure and estimation of risk which are discussed in Sections 3 and 4, respectively.

2.1 Physical Setting IRP Site 39/Harmon Substation is a 600-by-600-foot (approximately 8-acre) tract of vacant land located within the Harmon Annexes section of Andersen AFB. Figure 2 presents a map of the site in relation to the entire base and the island of Guam. Photographs of the site are presented in Attachment 1. The following information on the physical characteristics of IRP Site 39/Harmon Substation is based on information from various internal reports. The primary resources utilized were the "Agency Draft Site Characterization Summary Report for IRP Site 39/Harmon Substation" (EA, January 1998a) and the "Integrated Natural Resources Management Plan for Andersen Air Force Base, Guam" (USFWS, 1995). The physical characteristics of the site and surrounding area are included in this report so that potential receptors and potential exposure pathways for contaminants can be evaluated. Additional information associated with the physical setting of the site is presented in the Remediation Verification Report.

2.1.1 Climate Guam lies at 13°27' north latitude, approximately 900 miles north of the equator. Guam's climate is almost uniformly warm and humid year-round (USFWS, 1995). Temperatures on Guam generally range from 72 degrees Fahrenheit (°F) to 91 °F on a daily basis, with cooler temperatures during the dry season. Relative humidity is between 65-75 percent in the afternoon rising to 85-100 percent at night. There are generally two distinct climatic seasons on Guam. Rainfall is heaviest from July through November, with January through May considered the dry season. December and June are considered transitional months. Mean annual rainfall varies considerably among years, averaging 86 inches (in.). Approximately 20-25 percent falls in the dry season and 63-66 percent in the wet season with the remainder in the transitional months. Severe droughts and intense downpours can be expected on Guam. Large rain events associated

AU7-99/WP/Andersen.Eco-nsk_AppM_AgencyDraft.DOC 2-1 919689.21.00 60.30 7/28/99 5:02 PM with typhoons are not uncommon with as much as 24.9 in. of precipitation for a 24-hour period (Ward et al., 1965). The period of greatest drought hazard is February through April.

Winds are typically from the east at less than 10 miles per hour (mph) but are variable in late summer. Typhoons (winds from 75-150 mph) or supertyphoons (maximum surface winds over 150 mph) can hit Guam any time, but are more likely to occur during the rainy season with the highest frequency of occurrence from July through September. Wind damage, flooding, and high surf conditions can be associated with these storms.

2.1.2 Geology The island of Guam has two distinct physiographic provinces, the Northern Limestone Plateau and the Southern Volcanics. The Adelup Fault separates these two provinces. South of the fault, the island is composed almost entirely of volcanics, and north of the fault the island is composed almost entirely (excluding portions of Mt. Santa Rose) of limestone with karst topography (Marianas or Barrigada Formations).

The Harmon Annexes are situated on a limestone plateau with surficial karstic features. The surface geology consists of the Pliocene/Pleistocene-aged Mariana Limestone. The Mariana Limestone consists of four facies: (1) reefal facies comprised of massive corals which grew in situ (especially common to the cliff line) with cavernous and vuggy porosity; (2) detrital facies comprised of coarse to fine grain reefal detritus deposited lagoonal setting; (3) molluscan facies comprised of a fine grain detritus, with abundant casts and molds of mollusks and pelecypods, deposited in a lagoonal setting and (4) fore-reef facies comprised of well bedded friable to indurated white foraminiferal limestone deposited as fore-reef sand (Tracey et al., 1964).

The Miocene-aged Barrigada Limestone lies beneath the Mariana Limestone (approximately 300 to 400 feet [ft.] below ground surface [bgs]). It is the principal water bearing unit underlying the northern half of Guam, and it is highly permeable and porous with numerous voids, fissures, and solution openings. The Barrigada Limestone consists of a well-lithified to friable medium to coarse grain foraminiferal limestone (Tracey et al., 1964).

The Eocene/Oligocene-aged Alutom Formation unconformably underlies the Barrigada Limestone (approximately 600 to 800 ft. bgs) and consists of well bedded fine to coarse grain volcanic and volcaniclastic rocks (Tracey et al., 1964).

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDranDOC 2-3 919689.21.00.60.307/28/995:02 PM 2.1.3 Topography and Surface Water The Harmon Annexes are located on an undulating limestone plateau with sinkholes and other - karstic features. Due to the high permeability of the limestone, streams and surface waters do not exist. The nearest surface water body is the Philippine Sea, which is more than 1 mile west of the site. Topography at IRP Site 39/Harmon Substation is hummocky with man-made basins and mounds. The surface elevation ranges from 269 to 240 ft. above mean sea level. The overall gradient is slight (less than 3 percent) and slopes toward the north. The topography on the eastern portion of the site is undulating man-made mounds and depressions. The permeability and porosity of the limestone in this area is very high, and as a result, no rivers or streams are present.

2.1.4 Soil Guam has five major types of soils including laterite (volcanic soils); riverine mud; coral rock; coral sand; and argillaceous soils (mixtures of coral and laterite soils) (USFWS, 1995). At Andersen AFB, the substrate is primarily limestone. A thin layer of soil (approximately 4-10 in.) covers the northern limestone. Soils at Andersen AFB are rapidly drained, well aerated, highly alkaline, and high in calcium.

In the area of IRP Site 39/Harmon Substation, the undisturbed soil is a Guam cobbly clay loam. The loam is well drained and overlies porous limestone. Typically 5 to 10 percent of the surface is covered by gravels and cobbles (Young, 1988). The A horizon is characterized by a dark reddish clay loam about 6 in. thick. The B horizon is a dusky red gravelly clay loam about 6 in. thick. The C horizon or limestone bedrock, is often found at a range of 6 to 16 in. bgs. The soil is neutral to mildly alkaline, and permeability of the soil is moderately rapid. However, the soil at the site has been reworked and appears to be urban fill. In many areas, there is evidence that organic material such as plants and wood were burned. There is very little (if any) undisturbed Guam cobbly clay loam at the site.

2.1.5 Groundwater Groundwater in the Harmon Annexes and other portions of northern Guam occur as a freshwater lens lying above seawater, the two separated by a layer of brackish water. All precipitation, except that portion lost to evapotranspiration, contributes to the groundwater. The recharge to the aquifer by precipitation is estimated to average 0.77 million gallons/day/km2 (Mink, 1976).

Groundwater in the Harmon Annexes has been monitored for contaminants as part of the IRP. There are three groundwater monitoring wells (IRP-36, -37, and -38) and two public supply

AL/7-99/WP/Andeisen.Eco-nsk_AppM_AgencyDrafl.DOC 2-4 919689.21.00 60.30 7/28/99 5:02 PM wells (H-l and NCS-5) sampled biannually for volatile organic compounds (VOCs), Semivolatile organic compounds (SVOCs), pesticides, and metals. None of the wells are located on the site • and the closest well, ERP-35, is located approximately 4,100 ft. northwest of the site. Historical groundwater analytical results from the five wells have reported carbon disulfide and chloroform, which were attributed to laboratory contamination (the carbon disulfide was demonstrated to be the result of leaching from gloves used at the laboratory). Chromium and nickel concentrations were detected above their maximum contaminant level (MCL). These are suspected to be the result of corrosion of stainless steel screen and piston pumps. Trichloroethene was detected in a sample from H-l at a concentration less than its MCL. The most recent sample collected from H-l in April 1997, did not have detectable concentrations of VOCs, SVOCs, or pesticides.

2.1.6 Land use The property surrounding the Harmon Substation site is either for industrial use (including the substation) or is unused and moderately vegetated. The property is accessible to the public, but there is no residential use adjacent to the site. With the exception of the electric substation, and the petroleum, oils and lubricants (POL) and electrical right of ways, the surrounding properties are not developed and not utilized for recreation. The Micronesia Mall is located across Marine Drive, 800 ft. south of the site.

2.2 Ecological Setting The habitat at IRP Site 39/Harmon Substation is highly disturbed, with close to one-third of the site currently unvegetated as a result of remediation activities. Three types of disturbance communities are generally recognized as developing on disturbed ground on Guam. These are the Mixed Shrub Forest, the Mixed Herbaceous Vegetation, and the Elephant Grass (Pennisetum purpureum) Grassland (ICF Kaiser, 1996).. The current vegetation on the site is probably best described as Mixed Herbaceous Vegetation. Vegetation cover on the site is of low to moderate density, consisting of low-lying vines, sword grass, short grass, ferns and small trees. Part of the site has maintained grass and is used as a right of way for overhead electric conduit. Animals encountered at the IRP Site 39/Harmon Substation include monitor lizards (Varanus indicus), island gecko (Gehyra oceanic), Pacific slender-toed gecko (Nactus pelagicus}, Micronesian gecko (Perochirus ateles), Slevin's skink (Emoia slevinis), moth skink (Lipinia noctud), and brown tree snakes (Boiga irregularis). Although future succession of the plant community at the site is largely dependent upon future use or disturbance of the site and surrounding lands, it is not expected to revert to a native vegetation climax community.

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft DOC 2-5 919689.21.00.60.30 7/28/99 5.02 PM There are several threatened and endangered species on Guam; however, no federally endangered or threatened species or habitats of concern are associated with IRP Site 39 (Hirsh, - 1997; ICF, 1994). fable 1 lists the Federal and Guam Endangered species found on Andersen AFB.

2.3 Site History Historical aerial photographs and Air Force personnel interviews indicate the site was operated in the 1950s for the disposal of household and office wastes. Specific information on disposal practices and historical land use at the site is scant, though materials found at the site indicate it was used for surface disposal and "landfilling" of construction-related wastes (debris and metal containers), and electrical components. Excavation activities in 1989 related to a POL line provide some of the earliest details on the types of waste disposed of at IRP Site 39 (OHM, March 1998). Other, more specific information on the nature and extent of potential contaminants is available from investigation activities performed during 1997 (EA, January 1998b) and subsequent remediation and sampling activities performed during 1998. The information available from these sources is detailed below. Additional information regarding site history is presented in the Remediation Verification Report.

2.3.1 1989 POL Excavation The POL excavation activities along the northern edge of the site, as reported in an Action Memorandum (OHM, March 1998), uncovered "several containers." Subsequent soil sampling and analysis for PCBs revealed no detectable levels in the area. No other information was available for this excavation, nor does it appear that other types of sampling occurred at this time.

2.3.2 1997 Investigation The investigation and sampling activities detailed within the following subsections became the "drivers" for additional sampling activities. This section summarizes the findings from the 1997 investigation. Section 2.3.3 presents a summary of remediation and sampling activities at the site following this investigation.

2.3.2.1 Site Reconnaissance Site reconnaissance revealed that the site had been extensively excavated and graded as a landfill and small borrow area. The following types of items were discovered on the site: 5-gallon pails, 30- and 55-gallon steel drums (sometimes up to 5 layers of stacked drums), asphalt/tar seeps,

AL/7-99AVP/Anderscn:Eco-risk_AppM_AgcncyDraft.DOC 2-6 9l 9689.21.00.60.30 7/28/99 5:02 PM Table 1 List of Federal and Guam Endangered Species Found on Andersen Air Force Base3

Potential Presence Common Name Scientific Name Status13 IRP Site 39C Mammals

Little Mariana Fruit Bat Pteropus tokudae Endangered" No Mariana Fruit Bat Pteropus m. marianas Endangered No Birds

Vanikoro Swiftlet Aerodramas vanikorensis Endangered No barischi Mariana Common Moorhen Gallinola chioropuz guami Endangered No Guam Broadbill or Flycatcher Myiagra freycineti Endangered6 No Mariana Crow Corvus kubaryi Endangered No Guam Micronesian Kingfisher Halcyon c. cinnamomna Endangered6 No Guam Rail Rallus owstoni Endangered6 No Guam Bridled White-eye Zosterops c. conspicillata Endangered" Unlikely White-throated Ground Dove Gallicolumba x. xanthonura Guam Endangered" Unlikely Mariana Fruit Dove Ptilinopus roseicapilla Guam Endangered" No Micronesian Starling Alponis opaca guami Guam Endangered Unlikely Rufous-fronted Fantail Rhipidura nrfifrons uraniae Guam Endangered" No Cardinal Honeyeater Myzomela cardinalis saffordi Guam Endangered" No Trees

Hayun-lago Serianthes nelsonii Endangered No Ufa-haiomtano Heritiera longipetiolata Guam Endangered No Reptiles

Green Sea Turtle Chelonia mydas Threatened No Hawksbill Sea Turtle Eretmochelys imbricata Endangered No Leatherback Sea Turtle Dermochelys cariacea Endangered No

3 Source of information specific to Andersen Air Force Base is USAF (1995). Information on status was obtained from Virginia Tech (1998). 0 Information on the potential for a species to occur at a site was based on habitat information presented in Virginia Tech (1998) and Pratt, et al. (1989). d Presumed extinct on Guam. e In captive breeding programs. (No longer found in wild).

AL/7-99/WP/Andcrsen:Eco-nsk_AppM_AgcncyDraft.DOC 2-7 919689.21.00.60.30 7/28/99 5:02 PM electrical power components (including utility power poles), steel piping, nails, ash, an oil/water separator containing liquid and sludge, and a stormwater outfall.

2.3.2.2 Geophysical Survey and Excavated Test Trenches and Pits A geophysical survey indicated magnetic anomalies at the site and these areas (21) were excavated with test trenches. Other test trenches and pits were excavated to determine the extent of fill areas. The survey, in combination with the test trenches and pits excavated during the investigation uncovered similar materials as observed in the reconnaissance: buried drums, 5-gallon buckets, construction debris, and tar and asphalt. Some of the drums contained asphalt tar, while others were empty or their contents listed as "unknown." There are an "indeterminate number" of drums at the site. The fill areas appear to be limited to the northern portion of the site, which was used as a landfill and surface disposal area, and a portion of the west-central area of the site. Soil sampling (Section 1.2.4) was concentrated in these fill areas and around the stormwater outfall.

2.3.2.3 Soil Gas Survey Soil gas sampling for the presence of VOCs was performed at 33 grid node locations and suspected fill areas or mounds at approximately 4 ft. bgs. No target analytes were detected (see Basewide Sampling and Analysis Plan, Appendix A, Table A-l for a list of target analytes). A passive soil gas sampler was installed slightly north and west of the center of the site and allowed to record soil gas concentrations at approximately four feet bgs for 18 days. No VOCs were detected during this survey, either.

2.3.2.4 Soil Sampling Thirty-four surface and subsurface soil samples (0.25 - 10 ft. bgs) were collected at the site for SVOCs, metals, and total organic compounds. The subsurface soil samples were also analyzed for VOCs. Additionally, some of the 34 samples were selected for dioxin analysis. Surface samples were biased to fill areas and depressions. Subsurface samples were collected from the bottom of test trench excavations.

Samples from the fill areas indicated that PAHs and manganese were present above either EPA Region 9 Preliminary Remediation Goals (PRGs) or site-specific metals Background Threshold Values (BTVs). Dioxin concentrations exceeding PRGs were found adjacent to the stormwater outfall and in a sample of buried ash. Direct sampling of the oil/water separator indicated the presence of petroleum hydrocarbons, pesticides, and lead. Although no Resource Conservation and Recovery Act (RCRA) listed wastes were discovered during the sampling, the unknown

AL/7-99/WP/Andersen-Eco-nsk_AppM_AgencyDraft DOC 2-8 9'9689 21 00 60 30 7/28/99 5 02 PM contents of many of the drums precludes the assumption that no RCRA listed wastes are present at the site.

Metals. One sample contained a level of manganese which exceeded the BTV of 3,150 milligrams per kilogram (mg/kg). Mercury concentrations in five samples were detected in the range of 0.28-0.62 mg/kg, but were later qualified as "estimated values" due to the presence of mercury in the equipment blank.

SVOCs. SVOCs (particularly PAHs) were detected in ten samples, five of which exceeded PRGs. The following lists include all detected SVOC compounds not qualified as "estimated values":

• Fluoranthene - • Pyrene • Benzo(a)anthracene • Chrysene • Benzo(b)fluoranthene « Benzo(k)fluoranthene • Benzo(a)pyrene • Ideno(l,2,3-cd)pyrene • Dibenz(a,h)anthracene

Dioxins. Dioxins were detected in 14 of the 26 samples analyzed for dioxins. These "hits" were in the area designated as the landfill and in the stormwater outfall basin. The following three dioxins were identified: 1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin (HpCDD), 1,2,3,4,6,7,8,9-octachlorodibenzo-p-dioxin (OCDD), and 1,2,3,4,6,7,8-heptachloro-dibenzofuran (HpCDF).

2.3,2.5 Sludge and Water Sampling These samples were taken from the sediment (sludge) and water in a buried vessel believed to be an oil/water separator or a septic tank. A listing of detected metals, VOCs, SVOCs, pesticides, and PCBs is included below. Additionally, one water sample had a detectable level of total petroleum hydrocarbon (TPH)-diesel.

Metals. Copper, lead, and mercury were detected above the BTVs in one or both of the sludge samples. Iron and manganese were detected above secondary maximum concentration levels in two of three water samples.

AL77-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 2-9 919689.21.00.60.307/28/995:02 PM VOCs/SVOCs. Detectable levels of the following analytes were found in one sludge sample: 1,2,4-trimethylbenzene, 1,4-dichlorobenzene, and napthalene. Information for this same sludge - sample listed a detectable amount of 1,4-dichlorobenzene as an SVOC. One of the water samples contained detectable levels of toluene.

Pesticides/PCBs. The following pesticides/PCBs were detected in one or more of the sludge samples and one of the water samples:

• alpha-BHC • alpha-chlordane • gamma-chlordane • 4,4'-DDE • 4,4'-DDD • 4,4'-DDT • dieldrin • endrin • endrin aldehyde • enosulfan II

2.3.3 Post-1997 Excavation and Sampling History The field reconnaissance and sampling of 1997 provided target areas and contaminants for remediation activities conducted during 1998 and 1999. Table 2 details these activities. The following seven areas of the site were remediated: A6, C2, E6, the stormwater outfall, the oil/water separator location, the buried drum area, and the miscellaneous container area. Additionally, a site-wide sampling and analysis effort was completed to determine dioxin concentrations.

Remediation efforts at a given location were typically followed by the sampling of both the soil piles created during the excavation process (if any) and the in-place soils. Remediation continued until the sampling indicated that soil concentrations no longer exceeded the PRGs or BTVs set for the contaminants being removed. Thus, it can be expected that later sampling dates have lower levels of contaminants than those determined during earlier sampling efforts.

The oil/water separator excavation was backfilled using approximately 1,000 cubic yards of clean import fill and 100 cubic yards of soil that was removed during the excavation of the empty 55-gallon drums and piping situated immediately north of the oil/water separator. The 100 cubic yards of soil was characterized by sample number HAS39S278. This sample had

A177-99/WP/Anderscn:Eco-nsk_AppM_AgencyDraft-DOC 2-10 919689.21 00.60.30 7/28/99 5.02 PM Table 2 Summary of Excavation and Sampling Activities at IRP Site 39/Harmon Substation, 1998 and 1999

Sample Number of Samples Reported Date(sJ_ Sample Location Analyte(s) Samplesa'b As Memo Information0 Site Wide Surface Soil Sampling 7/16-7/17/98 Regular Grid Dioxins 5 (lab) EPA TEQ OHM 8/4-8/7/98 Locations Across Dioxins 15{labJ WHO TEQs 9/11/98 12/7/98 the Site Dioxins 7 (lab) WHO TEQs and 2/1 1/99 PAH Hot Spot at C2 7 (lab) Vanous PAHs and PCBs (lab) 5/19/98 PAHs/PCBs Total PAHs and 22 (field) OHM Grid Node C2 PCBs (field) 10/23/98 9/98 Excavation of PAH contaminated area 10 (lab) Various PAHs (lab) Post-excavation 9/11/98 confirmation 10 (field) Total PAHs (field) PAH Hot Spot at A6 Total PAH and 6/22/98 PAHs/PCBs 6 (lab) PCB 9/98 Excavation of PAH/PCB contaminated area OHM Grid Node A6 2 (lab) 10/26/98a Post-excavation Various PAHs (lab) 9/14/98 confirmation 2 (field) Total PAHs (field) PAH Hot Spot at Stormwater Outfall 5 (lab) Total TEQ, WHO TEQs and RGS 4/28/98 Dioxins Screen (lab) 20 (field) RGS Screen (field) 5 (lab) Total TEQ, WHO Grid Cell Bounded TEQs (lab) OHM 5/29/98 by Nodes A2, A3, PAHs/PCBs Total PAHs and 10/26/98b B2, and B3 18 (field) PCBs (field) 8/98 Excavation of contaminated area

9/1 and Post-excavation 4 (lab) Various PAHs 9/3/98 confirmation

PAH Hot Spot at E6 Total PAHs and 7/98 PAHs/PCBs 6 (field) Total PCBs OHM 8/98 Grid Node E6 Excavation of contaminated area 10/26/98C Post-excavation 8/14/98 3 (lab) Various PAHs confirmation Oil/Water Separator Confirmation > Total TRPH, Vanous 7/6/98 1" Confirmation and Total PCBs, and TRPH, PCBs, Lead 21 (lab and field) Event Total Lead (lab) Total PCBs (field] Vanous PCBs, 9/2/98 2* Confirmation PCBs, Pesticides, 22 Pesticides, PAHs, Event PAHs, Lead and Total Lead OHM Various PCBs, 11/19/98 3*° Confirmation PCBs, Pesticides, 10/5/98 11 Pesticides and Event PAHs, Lead PAHs

4lh Confirmation 10/21/98 Pesticides 1 Vanous Pesticides Event

AL/7-99/WP/AndeTsen:Eco-risk_AppM_AgcncyDran.DOC 2-11 919689.21.00.60.30 7/28/99 5:02 PM Table 2 (Continued) Summary of Excavation and Sampling Activities at IRP Site 39/Harmon Substation, 1998 and 1999

Sample Number of Samples Reported 3 0 Date(s) Sample Location Analyte(s) Samples * As Memo Information Buned Drum Area Remediation Confirmation Various PAHs and Sampling PAHs/PCBs 16 (lab and field) PCBs (lab) 8/28/98 st (1 Confirmation Total PAHsJfield) Event) Dioxins 8 (lab) WHO TEQs Potholes 9/25/98 PAHs 21 (field) Total PAHs Screening Various PAHs (lab) OHM Excavation Walls 3 (lab and field) 10/6-10/8/98 PAHs 12/4/98 Screening 24 (field) Total PAHs (field) Excavation Floor Confirmation Various PAHs (lab) 10/20/98 Sampling PAHs 10 (field and lab) nd Total PAHs (field) (2 Confirmation Event) 3™ Confirmation OHM 12/28/98 PAHs 8 (lab) Various PAHs Event 1/16/99 1/26 and Test Pit OHM PAHs 60 (lab) Various PAHs 1/28/99 Investigation 2/24/99 4"1 Confirmation 4/21/99 PAHs 16 (lab) Various PAHs Event No memo issued 5/5 and 5"1 Confirmation PAHs 8 (lab) Various PAHs 5/6/99 Event Miscellaneous Container Area 5 (lab) Various PAHs (lab) Segments 1 and 2 PAHs Confirmation jjjfield) Total PAHs (field) Sampling Dioxins 1 (lab) WHO TEQs 11/5/98 4 (lab) Various PAHs (lab) OHM Segments 1 and 2 PAHs 12/7/98 Soil Stockpiles 4 (field) Total PAHs (field) Dioxins 1 (lab) WHO TEQs Segment 1 11/6/98 PAH 8 (field) Total PAHs Screening VOCs. SVOCs, 12/1 5 and Segments 3 and 4, Pesticides, 5 (lab) Various Analytes 12/21/98 Confirmation PAHs/PCBs Sampling 12/21/98 Dioxins 1 (lab) WHO TEQs OHM VOCs, SVOCs, 1/22/99 12/1 5 and Pesticides, 5 (lab) Various Analytes 12/21/98 Segments 3 and 4, Soil Stockpiles PAHs/PCBs 12/21/98 Dioxins 1 (lab) WHO TEQs Power Pole Area, VOCs, SVOCs, 4/13/99 Soil Stockpiles Pesticides, 1 (lab) Various Analytes No memo issued PAHs/PCBs

Duplicates included in the count bLaboratory analyses and in-field screening tests are indicated as "lab" and "field", respectively. °The memo being referenced can be found in the References (Section 1.5).

AL/7-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 2-12 919689.21.00.60.30 7/28/99 5:02 PM detections of gamma-chlordane; 4,4'-DDD; 4,4'-DDE; 4,4'-DDT; and Aroclor-1260. Assuming an approximate 10:1 mixing of the clean fill with the on-site fill, the average concentrations of - these constituents within the backfill soil are all less than the average concentrations for all other soil samples from IRP Site 39 used to evaluate ecological risk (evaluating the Aroclors as total PCB concentration). Because of the rehandling of these soils, sample HAS39S278 was not included in the sample database used to evaluate ecological risk.

2.3.4 Data Validation Data used in this assessment were only from those samples relevant to the conditions of the site following past removal activities. Data validation is an after-the-fact, independent, systematic process of evaluating data. The validation process for data from Site 39/Harmon Substation was divided into two phases. The first phase considered field data to verify the completeness, accuracy, and representativeness of field sampling. The second phase dealt with analytical chemical validation. The important field data reviewed in the validation process were:

• Field logbooks • Specific field forms for sample collection and handling • Analytical Request/Chain-of-custody • Field instrument calibrations • Field personnel training • Variances and surveillance of field activities.

The primary analytical data and parameters reviewed in the validation process were:

• Organic constituent analyses:

- Holding times and preservation - Gas chromatography or high performance liquid chromatography performance - Initial and continuing instrument calibration - Surrogate recoveries - Internal standards - Method blanks - Laboratory control samples - Matrix spikes and matrix spike duplicates - Compound quantitation and identification - Field duplicate precision

• Inorganic constituent analyses:

- Holding times and preservation - Instrument performance checks

AL/7-99/WP/Andersen:Eco-risk_AppM_AgcncyDraft.DOC 2-13 919689.21.00.60.30 7/28/99 5:02 PM - Initial and continuing calibrations - Matrix spike and matrix spike duplicate evaluations - Inductively coupled plasma serial dilution and interference checks — Laboratory control sample checks - Duplicate sample analysis - Compound quantitation and identification - Field duplicate precision

A subset of the data was validated by a third party (Jacobs Engineering, Engineers and Constructors, Sacramento, California). The remaining sample data were validated by Contractor chemists assigned to the project experienced in data validations protocols. Detailed data quality assessment reports are available for all data packages containing data used for risk assessment purposes.

All post-remediation environmental sampling data were evaluated for suitability for use in the risk assessment. Analytical results for chemicals were reported using Air Force Center for Environmental Excellence and Contract Laboratory Program data qualifiers. Chemicals flagged with a "U" qualifier were considered to be not detected, or detected at a concentration below the normal, random "noise" of the analytical instrument. Estimated quantitative results such as those identified by a "J" qualifier are used in the assessment. The "J" qualifier describes an estimated value when a compound is present (spectral identification criteria are met), but at values less than the contract-required quantitation limit, or when quality control samples suggest that the sample results may be in error (e,g., when spike samples are outside of required limits or when holding times are just outside limits). Data with a "UJ" qualifier were treated as not detected for the purposes of data evaluation and risk assessment. If validation of the data reveals that samples must be rejected (assigned an "R" qualifier), the rejected data were not used for the risk assessment.

2.4 Constituents of Potential Ecological Concern Confirmatory sampling (summarized in Table 2) was conducted in 1998 and 1999 to address residual contamination in soil following the removal of PAH and PCB "hot spots" and other remediation actions. These samples formed the basis for this risk assessment. Samples were selected for inclusion in this assessment based on depth. The soil depth considered in this assessment is 0 to 5 ft. bgs, which is expected to be the depth interval where the potential for exposure to plants and wildlife is the greatest. When only composite boring samples encompassing this depth interval were available for a given area, these data were also used in the identification of COPECs and determination of exposure concentrations. The COPECs

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDrafl.DOC 2-14 919689.21.00.60.307/28/995:02 PM Table 3 Soil Sampling Results and Exposure Point Concentrations for Constituents of Potential Ecological Concern Andersen Air Force Base, Guam

Frequency of Maximum 95-percent UCL Constituent na Detection Concentration0 ConcentrationCld Inorganics Lead 11 91 5.65E+1 4.41E+1 Volatile and Semivolatlle Organics Acetone 7 43 3.70E-2 2.84E-2 Anthracene 53 11 2.94E-2 3.92E-3 Benzo(a)anthracene 54 41 4.88E+0 2.84E-1 Benzo(a)pyrene 53 42 8.75E-2 2.21 E-2 Benzo(b)fluoranthene 53 49 1.26E-1 3.23E-2 Benzo(k)fluoranthene 53 38 4.11E-2 1 .40E-2 Chrysene 53 38 4.11 E-2 1.40E-2 Dibenzo(a,h,)anthracene 52 2 4.80E-2 9.11E-3 Fluoranthene 60 30 1.99E-1 1.24E+0 lndeno(1 ,2,3-cd)pyrene 53 38 2.07E-1 3.42E-2 Methytene chloride 7 100 1.23E-2 9.49E-3 Phenanthrene 7 14 6.90E+0 4.41E-K) Pyrene 60 35 1.39E+1 9.89E-1 Pesticides gamma-Chiordane 18 17 1.90E-3 9.97E-4 I 4,4'-DDD 18 50 2.09E-2 9.78E-3 4,4'-DDE 18 89 1.35E+0 3.42E-1 4,4'-DDT 18 89 8.22E-2 3.99E-2 Dieldrin 18 28 8.50E-3 4.28E-3 Endrin aldehyde 18 6 5.00E-3 2.45E-3 Heptachlor epoxide 18 17 4.95E-3 1.59E-3 Polychlorinated Biphenyls Aroclor-1254 22 14 2.08E-1 4.61 E-2 Dioxins/Furans 2,3,7,8-TCDD 41 37 1.80E-6 5.30E-7 2,3,7,8-TCDF 41 71 9.70E-6 2.04E-6 1,2,3,7,8-PeCDD 41 66 3.67E-5 4.85E-6 1,2,3,7,8-PeCDF 41 56 4.35E-5 4.83E-6 2,3,4,7,8-PeCDF 41 59 4.47E-5 5.28E-6 1,2,3,4,7,8-HxCDD 41 73 1.46E-4 1.54E-5 1, 2,3,4 ,7,8-HxCDF 41 100 2.68E-4 3.44E-5 1 ,2,3,6,7,8-HxCDD 41 98 1.91E-3 1.64E-4 1,2,3,6,7,8-HxCDF 41 98 1.46E-4 1.78E-5 1,2,3,7,8,9-HxCDD 41 93 2.92E-4 3.45E-5 1,2.3,7,8,9-HxCDF 41 49 3.52E-5 4.67E-6 2,3,4,6,7,8-HxCDF 41 100 4.29E-4 4.53E-5 1,2,3,4,6,7,8-HpCDD 41 100 6.30E-2 5.27E-3 1, 2,3,4,6,7 ,8-HpCDF 41 100 3.88E-2 3.24E-3 1,2,3,4,7,8,9-HpCDF 36 69 1.54E-4 1.84E-5 OCDD 34 100 5.85E-1 5.82E-2 OCDF 34 100 3.01 E-1 2.74E-2

AL/7-99/WP/Andersen:Eco-risk_AppM_AgencyDran.DOC 2-15 919689.21.00.60.30 7/28/99 5:02 PM Table 3 (Concluded) Soil Sampling Results and Exposure Point Concentrations for Constituents of Potential Ecological Concern Andersen Air Force Base, Guam aNumber of samples used to determine exposure point concentrations for ecological receptors. In percent cln milligrams per kilogram soil. Nondetections were included at one half the reported detection limit UCL = Upper confidence limit of the mean.

Pesticides: DDD = 1,1-dichloro-2,2-bis(p-ch)orophenyl)ethane. DDE = 1,1-dichloro-2,2-bis(p-chlorophenyl)ethylene. DDT = 1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane.

Dioxins and furans: TC = Tetrachloro-. PeC = Pentachloro-. HxC = Hexachloro-. HpC = Heptachloro-. DD = dibenzo-p^dioxin. DF = dibenzofiuran.

A177-99/WP/Andersen:Eco-risk_AppM_AgencyDrafl.DOC 2-16 919689.21.00.60.30 7/28/99 5:02 PM identified for IRP Site 39/Harmon Substation are presented in Table 3. All detected organic analytes were included as COPECs. These consist of VOCs, SVOCs (all being PAHs), organochlorine pesticides, PCBs, and polychlorinated dibenzo-p-dioxins (PCDDs) and dibenzofurans (PCDFs). Lead (total) was the only inorganic analyte included in the confirmatory sample analyses and was included as a COPEC. Table 3 also lists the maximum measured concentrations from the samples evaluated for ecological risk and the 95-percent upper confidence limits (UCL) for the COPECs. The maximum concentration was used as the most conservative exposure point concentration, while the 95-percent UCL was used secondarily as a conservative estimate of the mean exposure concentration for the site. For statistical calculations, the nondetections were included at one half the reported detection limits.

2.5 Fate and Transport Potential The potential fate and transport of chemicals in surface and subsurface soils from IRP Site 39/Harmon Substation to other locations and media is of key significance in addressing potential exposure to ecological receptors at the site. As illustrated in the conceptual site model (Figure 3), surface water runoff is insignificant, infiltration/percolation into groundwater is expected to be insignificant at the site. No surface water bodies are adjacent to the site, therefore, transport to aquatic habitats is not expected to occur. Direct contact with contaminated soil is expected to be the major route of transfer of contaminants from environmental media to biota. Biota exposed to COPECs at the site may serve as a food source to higher trophic level organisms. This constitutes contaminant transport through the food web.

2.6 Ecological Receptors Ecological receptors in this evaluation were restricted to those species that use or have the potential to use the site either now or in the future. Because soils from the site contain compounds that can biomagnify through the food-chain, such as chlorinated pesticides, PCBs, dioxins, and furans, upper trophic level receptors were considered of greatest concern in this assessment. A generalized food web for the site is presented in Figure 4. The receptors, or groups of organisms selected, represent various levels of the trophic structure within the terrestrial habitat of IRP Site 39/Harmon Substation. As recommended by EPA (1997), trophic level position is emphasized to a greater extent than specific species in the selection of ecological receptors. Although specific species are used for exposure modeling purposes, the intent is to ensure protection of various species within a given trophic level. Emphasis is placed on indigenous/endemic species and special status species in the selection of trophic levels and receptor species. Because of the variety of plants at the site and the limited amount of phytotoxicity data available in the open literature, a generic terrestrial plant will be used to

AL/7-99/WP/Andersen.Eco-risk_AppM_AgencyDraft.DOC 2-17 919689.21.00.60.30 7/28/99 5:02 PM represent the plant species at the site. Wildlife receptors used to represent the major trophic levels at the site were: • Musk shrew (Suncus murinus)—insectivorous small mammal • Norway rat (Rattus norvegicus)—omnivorous small mammal • Feral dog (Canis familiaris)—predatory mammal • Mangrove monitor lizard (Varanus indicus)—predatory reptile • Micronesian starling (Aplonis opaca)—insectivorous bird

Musk Shrew. The musk shrew is found in Asia, as well as on Guam (McCoid et al., 1994). Not much is known about this particular species of shrew. Information about North American shrews, however, indicates the following about their life habits. They are small mammals that have high metabolic rates and can consume approximately their body weight in food each day (about 0.03 kg in the case of the musk shrew) (EPA, 1993; Silva and Downing, 1995). Most species are primarily vermivorous (consume earthworms) and insectivorous (consume insects), but some also eat small birds and mammals. Common food items of the shrew include earthworms, slugs, snails, and insects. Less common are plants, fungi, millipedes, centipedes, and arachnids. Shrews occupy a variety of habitats, including arid chaparral, open fields, woodlots, marshy wetlands, and forest streams. Some species burrow underground while others nest in tree stumps, logs, rocks, or debris piles (Burt and Grossenheider, 1976).

The musk shrew was selected as a receptor species because of its small size, high metabolic rate, terrestrial nature, and insectivorous diet. The small size of the shrew makes it likely that individuals of this species will have home ranges that are smaller than the Harmon Substation site (i.e., less than about 8 acres). Their high metabolic rates, and the consequently high food consumption rate, result in higher potential exposures to COPECs for shrews on the site. These exposures through food ingestion are further emphasized in this species by its insectivorous diet and, because it is terrestrial, by its expected high rate of incidental soil ingestion. The musk shrew is used to represent insectivorous mammals in the potential food web at IRP Site 39 and is used as a potential prey item for predators.

A177-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC 2-18 919689.21.00.60.30 7/28/99 5:02 PM PRIMARY SECONDARY PRIMARY RELEASE SECONDARY RECEPTOR SOURCES RELEASE PATHWAY MECHANISM SOURCES MECHANISM

BIOTA

Exposure Aquatic Route Terrestrial

Ingestion/ DIRECT CONTACT Uptake • Dermal O Contact

Residual Soil Surface and Contamination Ita Chemical Uptake by Near-Surface Food Web Ingestion from Past Migration Biota • Site Activities Soil

Uptake o C}

Ingestion Cj o Dermal Contact o o

Insignificant Pathway O Insignificant Exposure Pathway (not evaluated) O Minor Exposure Pathway (evaluated qualitatively) • Major Exposure Pathway (evaluated quantitatively) Figure 3 Conceptual Model for Terrestrial Habitat of IRP Site 39/Harmon Substation, Andersen Air Force Base, Guam Predatory Mammals and Reptiles

Herbivorous Herbivorous Omnivorous Omnivorous Insectivorous Insectivorous Birds Mammals Mammals Birds ' Mammals Birds n

(To All Wildlife Vegetation Receptors) Soil Invertebrates t

Figure 4 Generalized Food Web for the Terrestrial Habitat at IRP Site 39/Harmon Substation, Anderson Air Force Base, Guam Norway Rat. The Norway rat is common throughout the world in sewers and coastal wharfs. It flourishes in areas of commerce and urban human settlement. It is a relatively large rodent weighing about 0.25 kg and reaching 0.40 meter (m) in length. Most Norway rats are grayish- brown but it is also familiar as the white laboratory rat. Norway rats are poor climbers and seldom frequent trees. They nest in burrows less than two feet deep (Van Riper and Van Riper, 1982).

The Norway rat was selected as a receptor species to represent omnivorous mammals in the food web, which are likely to comprise a larger fraction of the diet of the predators at the site than are shrews. Like the shrew, the size of the Norway rat makes it likely that individuals of this species will have home ranges that are smaller than the Harmon Substation site. Their broader dietary habits and lower food requirements (per unit of body weight) provides a contrasting exposure scenario to that of the shrew for this site. This species represents potential risks to other species of rodents (particularly rats) that may inhabit the site.

Feral Dog. Feral dogs are domestic canines that have known little or no human contact. Not much is known about their activities on Guam. They range freely on other Pacific islands, sometimes in packs. These animals can be ferocious and on rare occasions have been known to attack humans. Feral packs tend to associate in areas where human settlements are established, such as at the edge of towns and cities (Van Riper and Van Riper, 1982). On Guam, feral dogs are said to have reached substantial densities. It has been estimated that the population reached 30,000 at one time. Prey items include herbivorous ungulates, such as pigs, sheep, and possibly even cattle where those are available. Other prey can include birds, domestic fowl, deer, rodents, and monitor lizards (McCoid et al., 1994; Van Riper and Van Riper, 1982). Body weight and size for Guam's feral dogs are unknown. Those on Hawaii are small, probably weighing about 12kg.

The feral dog was selected to represent the larger, mammalian predators in the food web at this site. Other such species include feral cats and (to some extent) feral pigs. These species have been introduced into the ecosystems of Guam and have probably been detrimental to the native species. Of these, only the feral pig is considered of economic value because it is hunted on the island. The feral dog, however, was selected to represent this trophic guild because its smaller size and more carnivorous diet will conservatively represent the exposures to the feral pig. Little is known of the numbers and importance of feral cats on Guam.

A177-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 2-21 919689.21.00.60.30 7/28/99 5:02 PM Mangrove Monitor Lizard. There are about 40 species of monitor lizards in the world. Approximately two-thirds of them are from Australia and the other third is from Africa, the Middle East, tropical Asia and some Pacific Islands (RHR, 1998). Monitors range in size from about 0.5 to 3 m in length. They are diumal and are most commonly found in aquatic habitats. Some monitors have been seen swimming in the ocean (Wildlife Associates, 1999). The mangrove monitor lizard, the only monitor species found on Guam, ranges geographically from extreme northeastern Australia, New Guinea, and the Solomon, Palau, Caroline, Marshall to the Mariana Islands (McCoid et al., 1994). Some authorities speculate that this species was introduced to Guam prehistorically, others estimate only 300 years ago. Evidence suggests that monitor populations have declined on Guam since the early 1960's (McCoid et al., 1994).

On Guam, the mangrove monitor lizard reaches 1.5 m in length. It is an omnivorous and opportunistic feeder. Documented prey items include insects, snails, rats, crabs, shrews, earthworms, slugs, skinks and geckos and their eggs, snakes, wild birds and their eggs, domestic fowl and their eggs, squid, toads, and the brown tree snake. The latter preys in turn on the mangrove monitor lizard (USAF, 1995; McCoid and Witteman, 1993; McCoid et al., 1994). Threats to the mangrove monitor lizard on Guam are believed to include the brown tree snake, poisonous toads, feral dogs, effects of urbanization, and the effects of introduced species, such as the declines in monitor's prey base caused by the introduced brown tree snake. It was selected as receptor in this risk assessment because it represents the largest terrestrial predator on the island that may predate European contact.

Micronesian starling. The Micronesian starling is a chunky, short-tailed black bird with a heavy, slightly curved bill. The subspecies Aplonis opacus guami is endemic to the Mariana Islands. This bird is not federally listed as threatened or endangered but is listed as endangered by the Government of Guam. It was once the most numerous land bird on the island, but is now found only in the housing areas at Andersen AFB and in the area to the south of the main base (USAF, 1995). The Micronesian starling feeds mainly on papaya fruit and seeds, but will also eat insects. It nests from January through June in the cavities of trees and rocky cliffs. Threats to its survival include the brown tree snake, rats, and monitor lizards.

The Micronesian starling was selected to represent insectivorous birds that may forage at IRP Site 39. Although its diet is more general, if not more herbivorous, than other possible choices, it was selected because it is native to Guam and is listed as endangered by the Government of Guam. In addition, it currently survives in and around urbanized areas of Andersen AFB and therefore, has a higher potential for occurring in the area of IRP Site 39 in the future if the

AL/7-99/WP/Andcrsen:Eco-risk_AppM_AgencyDraft.DOC 2-22 919689.21.00.60.307/28/995:02 PM populations can increase. Although the native yellow bittern (Ixobrychus sinensis} may also occur on site, use of the starling with similar food habits and smaller body weight make it a more conservative receptor for exposure/risk assessment purposes. Other native species that may fill similar roles are either highly limited in geographic range or possibly extinct. These include the Mariana crow (Corvus kubaryi), the Guam broadbill (Myiagra freycineti), and the rufous fantail (Rhipidura rufifrons). The Mariana crow was once common throughout Guam in forested areas and coconut plantations, but is now confined to the localized area of limestone cliff forests at Andersen AFB, with only about 50 individuals left (USAF, 1995). The Guam broadtail and rufous fantail may be extinct since none have been observed in recent years.

2.7 Exposure Pathways Routes of exposure for the ecological receptors are illustrated in Figure 3. Possible routes of exposure include:

• Dermal • Direct uptake by roots or through the shells of eggs • Ingestion • Inhalation

Ground nesting birds and lizards, small mammals, and rooting mammals, such as feral pigs, may be dermally exposed to COPECs in surface soil at the site. Dermal exposure to birds and small mammals is, however, expected to be limited because of their frequent grooming/preening activities. Reptiles periodically shed their outer skin, with the frequency of shedding dependent upon their growth rate. These provide mechanisms which are likely to reduce dermal exposure. In order to err on the side of conservatism, incidental ingestion of soil was conservatively overestimated in order to compensate for the absence of a quantitative evaluation of dermal exposure for these species.

Potential uptake through the shells of bird and reptile eggs is difficult to estimate because of the scarcity of data in this area. Researchers with the U.S. Geological Survey are currently investigating PCB uptake through turtle shells (e.g., Henry, 1998; Gale, 1999). Although these results have not yet been published, exposure to the developing embryo is much less than that expected to occur through biomagnification and subsequent transference from the gravid female to the egg (Gale, 1999). This route of exposure was not addressed in this screening assessment.

The more significant pathways are direct uptake and ingestion. Direct uptake of soil contaminants by plant roots is expected to occur at the site. Likewise, incidental ingestion of soil

AL/7-99/WP/Andersen:Eco-risk_AppM_AgencyDraft-DOC 2-23 9'9689-2' -00.60.30 7/28/99 5:02 PM by wildlife receptors and exposure through the food web are also anticipated. Because standing water does not exist at the site, exposure via consumption of water will not be addressed in this - assessment. In addition, exposure in wildlife through inhalation is also considered insignificant (Sample and Suter, 1994). Inhaled soil particles are likely to become trapped in the mucus lining of the nasal cavity and throat, which may lead to subsequent ingestion. Absorption of COPECs from soil particles directly through the lungs is also expected to be insignificant with respect to daily dietary intake of soil.

Potential exposure routes for each of the selected receptors and the means by which exposure will be addressed are presented below.

Dermal/Absorption Across Epidermis or Derrnis

• Generic plant—Exposure is semi-quantitatively addressed through bioaccumulation factors obtained from the literature.

• Micronesian starling—Dermal exposure is addressed through the use of a conservative soil ingestion rate.

• Musk shrew—Dermal exposure is addressed through the use of a conservative soil ingestion rate.

• Norway rat—Dermal exposure is addressed through the use of a conservative soil ingestion rate.

• Feral dog—Dermal exposure is addressed through the use of a conservative soil ingestion rate.

• Monitor lizard —Exposure is qualitatively addressed based on exposure of the starling and dog to COPECs in the environment.

Oral Ingestion

• Micronesian starling—Exposure is quantitatively evaluated as ingestion of earthworms and incidental ingestion of soil from the site.

• Musk shrew—Exposure is quantitatively evaluated as ingestion of earthworms and incidental ingestion of soil from the site.

• Norway rat- Exposure is quantitatively evaluated as ingestion of plants and earthworms and incidental ingestion of soil from the site.

AL/7-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 2-24 91968971.00.60.30 7/28/99 5 02 PM Feral dog—Exposure is quantitatively evaluated as consumption of plants, shrews, and rats and incidental ingestion of soil from the site.

Monitor lizard—Exposure is qualitatively addressed based on comparative exposures of the feral dog and Micronesian starling to COPECs in the environment.

2.8 Ecological Endpoints The overall management goal for this effort is to ensure the integrity of the biological community within the terrestrial habitats of IRP Site 39/Harmon Substation. Specifically, the goal is to ensure protection of populations of biota that may use the site at present or in the future. If a potential exists for a protected species to utilize the site in the future, then protection at the individual level is also necessary. Although no protected species are currently found on the site (Table 1), future recovery and expansion of such species (e.g., the Micronesian starling) could change this situation. In this assessment, however, the probability of this happening in the foreseeable future is considered small.

Assessment and measurement endpoints associated with the overall management goal are presented in Table 4. Assessment endpoints focus on key components within the food webs and on indigenous/endemic and protected species. Estimation of risk to plant populations is assessed through direct comparison of soil concentrations with phytoxicity benchmark values. Potential impacts on wildlife in this screening assessment are addressed through exposure modeling and the estimation of risk through the comparison of exposure estimates to literature-obtained

AL/7-99/WP/Andereen:Eco-risk_AppM_AgencyDrafl.DOC 2-25 91%89.21.00.60.30 7/28/99 5:02 PM Table 4 Ecological Endpoints IRP Site 39/Harmon Substation, Andersen Air Force Base, Guam

Management Goal Assessment Endpoint Measurement Endpoint • Ensure the integrity of • Toxicity of soil to plants. • Comparison of surface soil biological communities chemistry data with phytotoxicity within the terrestrial benchmark values. habitats of the site. • Toxicity of soil to terrestrial • Quotient method. wildlife. • Probability of wide-ranging receptors adversely impacted.

toxicity information. Potential impacts on the monitor lizard are assessed qualitatively using exposure and risk estimates for the feral dog and Micronesian starling as a conservative approximations of risk to the lizard. In all cases, the likelihood of exposure (e.g., with respect to degree or frequency of site use by the receptor) will also be used to evaluate potential risk to biota.

AU7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC 2-26 919689.21.00.60.30 7/28/99 5 02 PM 3.0 Analysis

The Analysis Phase of this evaluation process focuses on the estimation of exposure and the examination of toxicity data relevant to the COPECs and the ecological receptors of concern. These components are key to the evaluation of potential ecological risk. Because of the absence of site-specific biological monitoring data, exposure estimates in this assessment are based on conservative models, and all toxicity benchmarks are based on information obtained from the literature.

3.1 Exposure Characterization The purpose of exposure characterization is to describe the contact or co-occurrence of biota at the site with the COPECs. This effort focuses on specific ecological receptors and addresses the potential for these receptors to be exposed to COPECs associated with IRP Site 39/Harmon Substation. Ecological receptors that best represent biota associated with the habitats under investigation were selected in Section 2.6. Components related to exposure, such as the identification of pathways and the presentation of a conceptual model (Figure 3) and food web (Figure 4), are also presented in Section 2.

As described in Section 2.6, ecological receptors in this assessment are exclusively terrestrial. Plants that are exposed to COPECs through direct contact with potentially contaminated media do not require exposure modeling. Potential risk to these organisms will be evaluated by direct comparison of soil concentrations to toxicity benchmark concentrations for that medium.

For the shrew, rat, starling, dog, and monitor lizard the primary route of exposure was assumed to occur through ingestion of potentially contaminated food (prey organisms) and soil from the site. Therefore, the potential rate of exposure to COPECs was estimated through the modeling of COPEC transfer through the food web and to the target receptor. The exposure models described in this section are based on the habitat-specific food web shown in Figure 4. These were used to estimate the potential daily intake of COPECs by each of the wildlife receptors. Conservatisms were incorporated into the exposure modeling to ensure that the estimated exposures are more likely to overestimate the actual exposure rather than to underestimate it. Receptor-specific exposure parameters are presented in Table 5.

AU7-99/WP/AndeTsen:Eco-nsk_AppM_AgencyDran.DOC 3_| 919689.21.00.60.30 7/28/99 5.02 PM Table 5

3 Exposure Factors for Ecological Receptors IRP Site 39/Harmon Substation, I Andersen Air Force Base, Guam 70 I Receptor Trophic Body Weight Food Intake Incidental Soil Dietary Species Class/Order Level (kg)a Rateb Intake Composition0 Micronesian starling Aves/ Insectivore 0.0834° 0.0171 10.4%e Earthworms: 100% (Aplonis opaca) Passeriformes Musk shrew Mammalia/ Insectivore 0.03f 0.00489 13%n Earthworms: 100% (Suncus murinus) Insectivora Norway rat Mammalia/ Omnivore 0.250' 0.0140 2.4%J Plants: 50% (Raff us norvegicus) Rodentia Earthworms: 50% Feral dog Mammalia/ Carnivore 12.7K 0.555 2.8%' Plants: 5% (Canis familiaris) Carnivora Earthworms: 5% U) Shrews: 10% to Rats: 80% Mangrove monitor lizard Reptilia/ Squamata, Carnivore 2.2m 0.00499 4.5%" Animal prey: 100% (Varanus indicus) Sauria Body weights are in kilograms wet weight. In kilograms dry weight per day. Based on allometric equations from Nagy (1987), except where noted. °Dietary composition of feral dog based on information for the red fox from EPA (1993) with earthworms representing all invertebrates, shrews substituted for birds, and rats representing all mammal prey. The dietary composition for the monitor lizard is based on the animal prey with the highest COPEC concentration. All other species-specific estimations are based on general dietary trends and conservative assumptions. From Dunning (1993); mean of both sexes. eFrom Beyer et al. (1994) for American woodcocks. Vrorn Silva and Downing (1995); average of both sexes for Guam. 9Based on intake rate equal to body weight with a wet-weight to dry-weight conversion factor of 0.16 (EPA, 1993) S hFrom Talmage (1999). |From Silva and Downing (1995); mean of both sexes for Malaysia and Singapore. 'From Beyer et al. (1994) for the meadow vole. kFrom Sample et al. (1996). Standard weight for laboratory dog. 'From Beyer et al. (1994) for the red fox. mFromDryden(1965). i "From Beyer et al. (1994) for the box turtle. The potential daily intake of COPECs by each wildlife receptor (in milligrams per kilogram receptor body weight per day [mg/kg-d]) was estimated from the concentrations of COPECs in - each of the ingested media (prey and soil) and the daily ingestion rate of each medium by the receptor. The potential rate of exposure to specific compounds was determined as the sum of the compound-specific ingestion rates from all media. Conservatisms were incorporated into the modeling to ensure that the estimated exposures are more likely to overestimate the actual potential exposure rather than to underestimate it. The following describes the methods utilized for the modeling of exposure for the wildlife receptors.

Exposure of the bird and mammals through ingestion pathways was modeled using the methods described in the EPA's "Wildlife Exposure Factors Handbook" (EPA, 1993). The basic model for estimating the daily intake of a COPEC per kilogram of body weight (i.e., the estimated daily dose of the COPEC) through the ingestion pathway is as follows:

where:

DRX = the estimated daily dose (mg/kg-day) of COPECs x in wildlife receptor R da = the concentration of COPECs x in the kth food type, including soil as one of these types (in mg/kg dry weight for food and soil) Fk = the fraction of the kth food type that is comes from the contaminated site (assumed to be 1.0) Ik = the ingestion rate of the kth food type (kg dry weight/day for food and soil) N = the number of food items in the wildlife diet (including soil)

BWR = the body weight of wildlife R (kg wet weight)

When multiple food items were included in the diet, Ik was determined by multiplying the total food ingestion rate of the receptor by the fraction of the diet composed of food item k. In th? case of soil, Ik was determined by multiplying the total food ingestion rate by the percent incidental soil ingestion.

COPEC concentrations in plants, earthworms, shrews, and rats were modeled from the soil concentrations used as the exposure point concentrations (either the maximum soil concentration

AL/7-99/WP/Andcrsen:Eco-nsk_AppM_AgencyDraftDOC 3.3 919689.21.00.60.307/28/995:02 PM or the 95-percent UCL. These were generally modeled as linear relationships using transfer factors; however, some were derived using empirically-derived nonlinear uptake models. Table 6 presents the transfer factors for the linear models and Table 7 presents the parameters for the nonlinear models. For lead, the transfer factor for plants was from the National Council on Radiation Protection and Measurement (NCRP, 1989), while the concentrations in the earthworms and small mammals were based on nonlinear models (Sample et al., 1998a and 1998b). The transfer factors for the organic COPECs were principally derived from the logarithm (log) of the octanol/ water partion coefficient (KoW), using the regression equation from Travis and Arms (1988) for the soil-to-plant transfer factor, the equation developed by Connell and Markwell (1990) for the soil-to-earthworm transfer factor, and the geometric mean regression equation derived from data presented in Garten and Trabalka (1983) for small mammals. The fraction of organic carbon in soil was conservatively estimated at 1.1 percent for the Connell and Markwell equation. Soil samples from Operable Unit 3 showed total organic carbon ranging from 1.1 to 12.2 percent (ICF Kaiser, 1996), with a mean of seven median values of 4.2 percent. A fraction of body fat was conservatively estimated at 25 percent for the estimation of whole-body COPEC concentrations in the shrew and rat. The soil-to-earthworm transfer factors for 4,4'-DDD; 4,4'-DDE; and 4,4'-DDT were set at 0.26 based on measured uptake reported by Beyer and Gish (1980). Dioxins and furans (as TCDD equivalent [see Section 3.2.2]) and PCB concentrations in earthworms and dioxins and furans (as TCDD equivalent) concentrations in small mammals were estimated using nonlinear models (Sample, et al., 1998a; Sample, et al., 1998b).

In this assessment, exposures were initially calculated under the conservative assumption that 100% of the animal's ingestion comes from the point of maximum COPEC concentration (F* equal to 1.0). Ninety-five percent UCL values, as exposure point concentrations, were also used to provide a more realistic estimate of potential risk. The maximum and 95-percent UCL concentrations of the COPECs are presented in Table 3. In addition, the potential effects of foraging range and seasonal use on this conservative estimation are discussed in the uncertainty and ecological significance sections of the report.

3.2 Ecological Effects Evaluation Toxicological information was obtained from several sources in order to assess potential ecological risk to biota at this site following exposure to the COPECs. Plant toxicity information was primarily extracted from Efroymson et al. (1997). Wildlife toxicity reference values were derived for birds and mammals using information presented in Sample et al. (1996) and other

Air7-99/WP/Andcrscn:Eco-risk_AppM_AgencyDrafl.DOC 3.4 919689.21.00.60.307/28/995:02 PM Table 6 Transfer Factors for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

Soil-to-Plant Soil-to-Earthworm Small Mammal a b 0 d Constituent log KoW Transfer Factor Transfer Factor Uptake Factor Inorganic Lead | NA 9.00E-2 ML NL Volatile and Semivolatile Organ ics Acetone -0.24 5.33E+1 1.13E+0 1.77E-6 Anthracene 4.45 1.04E-1 1 .93E+0 2.13E-2 Benzo(a)anthracene 5.61 2.22E-2 2.21E+0 2.17E-1 Benzo(a)pyrene 6.11 1.14E-2 2.34E+0 5.91 E-1 Benzo(b)fluoranthene 6.57 6.17E-3 2.47E+0 1.48E+0 Benzo(k)fiuoranthene 6.84 4.31 E-3 2.54E+0 2.55E+0 Chrysene 5.91 1.49E-2 2.28 E+0 3.96E-1 Dibenzo(a,h,)anthracene 6.50 6.78E-3 2.45E+0 1 .29E+0 Fluoranthene 4.90 5.70E-2 2.03E+0 5.24 E-2 indeno(1 ,2,3-cd)pyrene 6.58 6.09E-3 2.47E+0 1.51E+0 Methylene chloride 1.25 7.34E+0 1 .34E+0 3.50E-5 Phenanthrene 4.57 8.84E-2 1 .96E+0 2.70E-2 Pyrene 5.32 3.26E-2 2.13E+0 1.21 E-1 Pesticides gamma-Chlordane 6.32 8.61 E-3 2.40E+0 9.00E-1 4,4'-DDD 6.53 6.51 E-3 2.60E-1e 1.37E+0 4,4'-DDE 6.53 6.51 E-3 2.60E-1e 1.37E+0 4,4'-DDT 6.53 6.51 E-3 2.60E-1* 1.37E+0 Dieldrin 5.37 3.05E-2 2.15E+0 1 .34E-1 Endrin aldehyde 5.06 4.61 E-2 2.07E+0 7.21 E-2 Heptachlor epoxide 5.00 4.99E-2 2.06E+0 6.40E-2 Polychlorinated Biphenyls Aroclor-1254 6.04 1 .25E-2 NL 5.14E-1 Dioxins/Furans TCDD 7.02 3.39E-3 NL NL Logarithm of the octanol-water partition coefficient (used only with organic constituents). For organics, based on regression equation from Travis and Arms (1988). The value for lead from NCRP (1989). Calculated from the octanol-water partition coefficient based on the equation from Connell and Markwell (1990), except where noted. Based on regression of rodent uptake factors presented in Garten and Trabalka (1983) with octanol- water partition coefficient. eFrom Beyer and Gish (1980).

NL indicates nonlinear uptake model used (see Table 7 for modeling parameters).

AL/7-99/WP/Andersen:Eco-risk_AppM_Agency Dratt.DOC 3-5 919689.21.00.60.30 7/28/99 5:02 PM Table 7 Nonlinear Model Parameters for Modeling Constituents of Potential Ecological Concern in Earthworm and Mammal Tissues3 Andersen Air Force Base, Guam

Constituent Bo B, Earthworm models Lead -0.2180 0.807 PCB (Aroclor-1254) 1.410 1.361 TCDD 3.533 1.182 Musk shrew models0 Lead 0.4819 0.4869 TCDD 0.8113 1 .0993 Norway rat models0 Lead 0.0761 0.4422 TCDD 0.8113 1 .0993

Models are of the form: In [tissue concentration] = B0 +61 In [soil concentration], with concentrations expressed as mg/kg dry weight and In is the natural logarithm. bFrom Sample et al. (1998a). °From Sample et al. (1998b). literature sources and electronic databases (e.g., EPA, 1999). Much of the toxicological information used in ecological screening assessments has been summarized elsewhere (e.g., Eisler and Belisle, 1996; Eisler, 1986; Sample et al., 1996). This section addresses the specific toxicity-based reference values used in this assessment. The methodology used to derive benchmark values in the absence of published values is also presented.

3.2.1 Plant Toxicity Reference Values Plant toxicity benchmarks are primarily based on the information provided in Efroymson et al. (1997) and (for PAHs) from Sims and Overcash (1983). The former are based on lowest- observed-adverse-effect-levels (LOAEL) using 20 percent reduction in growth as the endpoint and are limited to tests in soil, rather than tests using solutions. Although based on LOAELs, these benchmarks are considered conservative and appropriate to the screening level assessment. The endpoint is sublethal and reductions in plant growth may have no significant effects on the reproductive potential or the continued existence of a plant population. Futhermore, these benchmarks are primarily based on studies in which the chemical of interest is added freshly to a soil (in the case or inorganics, often as the most soluble salt) and is typically more bioavailable than the COPECs that have had a chance to bind with soil particles or are in a less soluble form. Toxicity values specific to plants are presented in Table 8.

Al/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC 3-6 919689.21.00 60 30 7/28/99 5 02 PM 3.2.2 Wildlife Toxicity Reference Values As recommended by EPA (1997), no-observed-adverse-effects levels (NOAEL) for chronic oral exposure were used as benchmarks for toxic effects to wildlife (Table 8). NOAELs are defined as the maximum dosage tested that produced no effect that would be considered adverse to the long-term viability of the population. Therefore, the endpoints of particular interest in the underlying studies are those associated with reproductive health, development, and mortality. The methodology used to derive receptor-specific NOAELs is described below (Sample et al., 1996).

BWT NOAEL* = NOAELr where:

NOAELw = the no-observed-adverse-effect-level for the wildlife receptor species (mg/kg-day) NOAELy = the no-observed-adverse-effect-level for the test species (mg/kg-day) BWj = the body weight of the test species (kg) BWw = the body weight of the wildlife receptor species (kg) s = the class-specific scaling factor (s = 0.06 for mammals and —0.20 for birds [Sample and Arenal, 1999])

Toxicity studies were considered to be chronic if they are conducted over a period of 26 weeks (one half year) or more. Studies of lesser duration (i.e., 1 to 25 weeks) were considered subchronic, unless they specifically included reproductive effects as endpoints (Sample et al., 1996). When only subchronic oral NOAEL values were available, they were converted to chronic NOAEL values by applying an uncertainty factor of 0.1 (Sample et al., 1996).

In cases when only a chronic LOAEL value was available for test data, an uncertainty factor of 0.1 is used to convert it to the chronic NOAEL. If only a subchronic LOAEL was available, then an uncertainty factor of 0.01 is used to estimate the chronic NOAEL. This uncertainty factor is the product of two uncertainty factors of 0.1, one to convert the subchronic value to a chronic value and the other to convert the LOAEL to an NOAEL.

919689 21 00 60.30 7/28/99 5 02 PM AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraftDOC 3-7 Table 8

-a Toxicity Benchmark Information for Constituents of Potential I Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

Mammalian NOAELs Avian NOAELs n Constituent of Potential Plant Mammalian Test Species Test Species Avian Test Species Test Species Ecological Concern Benchmark Test Species NOAELb'° Body Weightb-d Test Species NOAELb'c Body WeightM Inorganic e Lead 50 Rat 8.0 0.35 Japanese quail 1.13 0.15 Volatile and Semivolatlle Organics

f ___ Acetone Rat 10.0 0.35 — 9 h h Anthracene 18 Mouse 100 0.03 ... 9 Benzo(a)anthracene 18 Mouse' 1.0' 0.03 9 Benzo(a)pyrene 18 Mouse 1.0 0.03 — 9 oo Benzo(b)fluoranthene 18 Mouse 1.0' 0.03 _. ... 9 ._ ... Benzo(k)f!uoranthene 18 Mouse 1.0' 0.03 — 9 Chrysene 18 Mouse 1.0' 0.03 9 __ — Dibenzo(a,h)anthracene 18 Mouse 1.0' 1.06 — 8 ,. h h — Fluoranthene 18 Mouse 12.5 0.03 ... — - lndeno(1 ,2,3-cd)pyrene 18° Mouse 1.0' 0.03 — ~_ ... Methylene chloride Rat 5.85 0.35 —. ™ 9 Phenanthrene 18 Mouse 1.0' 0.03 ... — 9 h Pyrene 18 Mouse 7.5 0.03 ~~ .„ ... Pesticides gamma-Chlordane ._ Mouse 4.6 0.03 Red-winged blackbird 2.14 0.064 4,4'-DDD — Rat 0.8 0.35 Brown pelican 0.0028 3.5 4,4'-DDE — Rat 0.8 0.35 Brown pelican 0.0028 3.5 4,4'-DDT — Rat 0.8 0.35 Brown pelican 0.0028 3.5 Pesticides Dieldrin ._ Rat 0.02 0.35 Barn owl 0.077 0.466 Endrin aldehyde — Mouse 0.092 0.03 Screech owl 0.01 0.181

I? "* > s Table 8 (Continued) Toxicity Benchmark Information for Constituents of Potential I Ecological Concern at IRP Site 39, Harmon Substation o. 3 Andersen Air Force Base, Guam 3 2 Mammalian NOAELs Avian NOAELs Constituent of Potential Plant Mammalian Test Species Test Species Avian Test Species Test Species Ecological Concern Benchmark8 Test Species NOAELb'° BodyWeightM Test Species NOAELb'° BodyVVelghtb'd

Heptachlor epoxide Mink 0.1 1.0 ___ . Polychlorinated Biphenyls Aroclor 1254 406 Oldfield mouse 0.068 0.014 Ring-necked pheasant 0.18 10 Dioxins/Furans 2.3,7,8-TCDD Rat 0.000001 0.35 Ring-necked pheasant | 2.14 1.0

In milligrams per kilogram soil. From Sample et al. (1996), except where noted. cln milligrams per kilogram body weight per day. In kilograms. "From Efroymson etal. (1997). — designates insufficient toxicity data. 9From Sims and Overcash (1983). Based upon a toxicity Information from EPA (1999), Insufficient toxicity data available for this compound. The NOAEL for benzo(a)pyrene is used as a default, 'insufficient toxicity data available for this compound. The NOAEL for edrin is used as a default. Nnsufficient toxicity data available for this compound. The NOAEL for heptachlor Is used as a default.

0X0 VO oO 8 UJ o

T) When possible, NOAELs for the wildlife receptor species were derived from test species that are taxonomically close to the target receptor. Therefore, bird NOAELs were derived from avian - test species and mammal NOAELs were derived from mammalian test species. The chemical- specific NOAELs from toxicity studies that were used to derive toxicity reference values for the shrew, rat, dog, and starling are presented in Table 8.

Total dioxin-like toxicity for the wildlife receptors was based on the usage of wildlife toxicity equivalency factors (TEF) for PCDDs and PCDFs, as recommended by the World Health Organization (Van den Berg et al., 1998; EPA, 1998b). These TEFs are presented in Table 9. TEFs were multiplied by site-specific concentrations measured in soil and the summed toxicity equivalency (TEQ) used in the estimation of exposure. The toxicity values specific to 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD) was used as the reference value is assessing the potential risk from exposure to all dioxins/furans.

3.2.3 Reptilian Toxicity Data Toxicological effects data for lizards and reptiles, in general, are very limited (Meyers-Schone, in prep.). Available data are primarily limited to radiation dose and biomarker studies with little information on how such effects relate to survival or reproduction, key toxicity endpoints for the evaluation of potential population level effects. Most reptilian toxicity data is specific to turtles. Information relevant to the PCBs indicate that turtles are able to store high concentrations of chlorinated organics (e.g., PCBs and organochlorine pesticides) in fat tissues without apparent adverse effects (Bishop et al., 1995). This may be associated with lower amounts of liver microoxygenase activity in turtles than in mammals (Walker and Ronis, 1989). In addition, the toxicity of organophosphate pesticides to reptiles appears more similar to that of birds than mammals (Hall and Clark, 1982). Because of the scarcity of reptilian ecotoxicological data and the evidence that, in some cases, reptiles may be as or less sensitive to specific chemicals than birds and mammals, potential risks to the monitor lizard was qualitatively assessed using the risk results from the Micronesian starling and feral dog.

AL/7-99/WP/Andersen Eco-nsk_AppM_AgencyDraft DOC 3-10 919689.21 00.60.30 7/28/99 5 02 PM Table 9 TCDD Toxicity Equivalency Factors for the Birds and Mammals3

Dioxin/Furan Mammalian TEF Avian TEF 1,2,3,4,6,7,8-HpCDD 0.01 <0.001 1,2,3,4,6,7,8-HpCDF 0.01 0.01 1,2,3,4,7,8,9-HpCDF 0.01 0.01 1,2,3,4,7,8-HxCDD 0.1 0.05 1,2,3,4,7,8-HxCDF 0.1 0.1 1, 2,3,6,7,8-HxCDD 0.1 0.01 1,2,3,6,7,8-HxCDF 0.1 0.1 1, 2,3,7, 8,9-HxCDD 0.01 0.01 1,2,3,7,8,9-HxCDF 0.1 0.1 1,2,3,7,8-PeCDD 1 1 1,2,3,7,8-PeCDF 0.05 0.1 2,3,4,6,7,8-HxCDF 0.1 0.1 2,3,4,7,8-PeCDF 0.5 1 2,3,7,8-TCDD 1 1 2,3,7,8-TCDF 0.1 0.1 OCDD 0.0001 — OCDF 0.0001 0.0001 aToxicity equivalency factors from EPA (1998b) and Van den Berg (1998). HpCDD = Heptachlorodibenzo-p-dioxin. HpCDF = Heptachlorodibenzofuran. HxCDD = Hexachlorodibenzo-p-dioxin. HxCDF = Hexachlorodibenzofuran. OCDD = Octachlorodibenzo-p-dioxin. OCDF = Octachlorodibenzofuran. PeCDD = Pentachlorodibenzo-p-dioxin. PeCDF = Pentachlorodibenzofuran. TCDD = Tetrachlorodibenzo-p-dioxin. TCDF = Tetrachlorodibenzofuran. TEF = Toxicity Equivalency Factor.

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgcncyDraftDOC 3-11 919689.21.00 60.30 7/28/99 5.02 PM 4.0 Risk Characterization

The assessment of potential risk is the culmination of the screening assessment. Risk characterization in this assessment is divided into a direct comparison of estimated exposures to toxicity-based benchmark screening values (the hazard quotient [HQ] assessment), an analysis of the uncertainties associated with the HQ predictions of risk, and a final evaluation of the ecological significance associated with the prediction of potential risk. The HQs are based on exposures estimated from both the maximum and 95-percent UCL soil concentrations.

4.1 Risk Estimation Potential risks to a trophic level are inferred when exposure to a particular receptor species is in excess of the benchmark. Specific comparisons include the following:

• COPEC concentrations in soil samples compared to plant benchmark values (as HQs).

• HQs for wildlife

• Risk to the monitor lizard based on comparisons of exposures to those of the Micronesian starling and feral dog.

HQs were used to evaluate potential risks to plants, musk shrew, Norway rat, Micronesian starling, and feral dog. HQs are specific to a particular receptor for exposure to a particular COPEC. For the sword grass, the HQ is the ratio of the soil concentration to the plant toxicity benchmark concentration. For the wildlife receptors, the HQ is defined by:

ExP°sure Benchmark where:

HQ = the hazard quotient (unitless) Exposure = the estimated dose of the COPEC for the receptor (in mg/kg-day) Benchmark = the toxicological benchmark for the COPEC and receptor (in mg/kg-day)

AU7-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 4,] 919689.21.00.60.307/28/995:02 PM The HQ is greater than 1.0 when the estimated exposure to a COPEC for a receptor exceeds the toxicological benchmark for that receptor. Because conservatism is employed to generally overestimate exposure and underestimate the toxicity threshold represented by the benchmark, HQ values greater than 1.0 do not necessarily indicate risk to the receptor; however, increasing magnitude of the HQ above 1.0 indicates an increasing potential that risk may exist. HQ values less than 1.0 were used to justify the exclusion of specific receptor/chemical pairs from further consideration.

4.2 Risk Results Table 10 presents the HQs for the ecological receptors modeled at IRP Site 39/Harmon Substation based on exposure point concentrations represented by the maximum measured soil concentrations. Based on the maximum concentrations, HQs for the plant were slightly greater than 1 for lead and fluoranthene. Due to the lack of plant toxicity information, HQs for plant could not be determined for the VOCs (acetone and methylene chloride), pesticides, and dioxins/furans. In the musk shrew, HQs greater than 1 were found for benzo(a)anthracene, phenanthrene, Aroclor-1254, and TCDD, with the first three being less than 3 and the last being greater than 2,000. The Micronesian starling showed HQs greater than 1 for lead; 4,4'-DDD; 4,4'-DDE; 4,4'-DDT, and TCDD, although HQs for this receptor could not be determined for any of the VOCs, SVOCs, and heptachlor epoxide due to the lack of avian-specific toxicity data. The HQs for 4,4'-DDE and TCDD were relatively high (76 and 152, respectively) for this receptor. In the Norway rat and the feral dog, only the HQ for TCDD exceeded unity; however, the values for these HQs were 422 and 128, respectively. The COPECs that did not show HQs greater than unity when the exposures were based on the maximum measured soil concentrations were dropped from further consideration as potential ecological risk drivers in this assessment.

Table 11 presents the HQs for the ecological receptors modeled at IRP Site 39/Harmon Substation with the 95-percent UCL being used as the exposure point concentration. For these cases (limited to those COPECs that indicated potential risk based on the maximum soil concentrations), none of the HQs for plants exceed unity. HQs for phenanthrene and TCDD still exceed unity for the musk shrew, the former being less than 2, but the latter exceeding 100. In both the Norway rat and feral dog, only TCDD showed HQs greater than unity (24.3 and 8.5, respectively). With the exception of 4,4'-DDD, the Micronesian starling had HQs greater than 1 for the same COPECs as found with the exposures to the maximum concentrations; however, the HQs for TCDD and 4,4'-DDT were less than 10, and that for 4,4'-DDE was less than 20.

AU7-99/WP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 4_ 919689.21.00.60.30 7/28/99 5:02 PM Table 10 Hazard Quotients Based on Exposures to Maximum Measured . Soil Concentrations for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

Musk Norway Micronesian Feral Constituent Plant Shrew Rat Starling Dog Inorganics Lead | 1.13E+0 4.87E-1 | 9.81 E-2 | 5.45E+0 6.22E-2 Volatile and Semivolatile Organics — Acetone — 6.41E-4 5.52E-3 5.52 E-4 Anthracene 1 .63E-3 9.70E-5 1 .94E-5 — 3.62E-6 Benzo(a)anthracene 2.71E-1 1.82E-H) 3.53E-1 — 2.71 E-1 Benzo(a)pyrene 4.86E-3 3.45E-2 6.65E-3 — 1 .25E-2 Benzo(b)fluoranthene 7.00E-3 5.23E-2 1.01 E-2 — 4.58E-2 Benzo(k)fiuoranthene 2.28 E-3 1.76 E-2 3.39E-3 — 2. 61 E-2 Chrysene 2. 28 E-3 1 .59E-2 3.06E-3 — L3.98E-3 Dibenzo(a,h,)anthracene 2.67E-3 1.98E-2 3.81 E-3 — 1.51 E-2 Fluoranthene 1.11E+0 5.51 E-1 1 .08E-1 — 3.01 E-2 lndeno(1 ,2,3-cd)pyrene 1.15E-2 8.60E-2 1.66E-2 7.68E-2 __ — Methylene chloride 4.26E-5 5.02E-5 — 5.27E-6 Phenanthrene 3.83E-1 2.31 E+0 4.59E-1 — 9.32E-2 Pyrene 7.72E-1 6.72E-1 1.30E-1 — 6.30E-2 Pesticides gamma-Chlordane — 1.67E-4 3.22E-5 4.31 E-4 9.01 E-5 4,4'-DDD — 1.41 E-3 2.25E-4 1.18E+0 1.01 E-3 4,4'-DDE — 9.09E-2 1 .45E-2 7.60E+2 6.54E-2 4,4-DDT — 5.53E-3 8.86E-4 4.62E+1 3.98E-3 Dieldrin — 1.34E-1 2.59E-2 7.19E-2 1.35E-2 Endrin aldehyde — 1.91 E-2 3.74 E-3 2.60E-1 1.26E-3 Heptachlor epoxide — 1 .40E-2 2.75E-3 — 8.58E-4 Polychlorinated Biphenyfs Aroclor-1254 j 5.20E-3 1.26E+0 2.42E-1 9.45E-1 3.99E-1 Dioxins/Furans TCDD equivalent | — 2.14E+3 4.22E+2 1.52E+2 1.28E+2 Bold indicates hazards quotients greater than 1. — indicates insufficient toxicity information to determine the hazard quotient.

AL/7-99/WP/Andereen:Eco-risk_AppM_AgencyDrafl.DOC 4-3 919689.21.00.60.30 7/28/99 5:02 PM Table 11 Hazard Quotients Based on Exposures to 95-Percent Upper Confidence Limit Soil Concentrations for Constituents of Potential Ecological Concern at IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

Musk Norway Micronesian Feral Constituent Plant Shrew Rat Starling Dog Inorganics Lead 8.82E-1 3.94 E-1 ^ 7.93E-2 4.42E+0 5.37E-2 Volatile and Semivolatiie Organics Benzo(a )anthracene 1.58E-2 1 .06E-1 2.05E-2 — 1 .58E-2 Fluoranthene 6.89E-2 3.43E-2 6.74E-3 — 1.87E-3 Phenanthrene 2.45E-1 1.47E+0 2.93E-1 — 5.96E-2 Pesticides 4,4'-DDD — 6.58E-4 1.05E-4 5.50E-1 4.74E-4 4,4'-DDE — 2.30E-2 3.68E-3 1.92E+1 1 .66E-2 4,4'-DDT — 2.69 E-3 4.30E^ 2.24 E+0 1 .93 E-3 Polychlorinated Biphenyls Aroclor-1254 | 1.15E-3 1.68E-1 3.18E-2 1.25E-1 8.63E-2 Dioxins/Furans TCDD equivalent — 1.24E+2 2.43E+1 9.41 E+0 8.50E+0 Bold indicates hazards quotients greater than 1. — indicates insufficient toxicity information to determine the hazard quotient.

Because of the lack of reptile-specific toxicity information, HQs for the mangrove monitor lizard could not be calculated. However, potential risk to this receptor was evaluated qualitatively by comparison of the exposure rates (in mg/kg-d) of the monitor with those of the Micronesian starling and feral dog. Table 12 presents these exposure rates. Based on the study by Dryden (1965), the mangrove monitor lizard has a diverse diet, including both invertebrates and vertebrates; however, plants were not recorded in the stomachs of these lizards except as detritus. Therefore, the monitor lizard's exposure was based on a diet consisting entirely of one animal prey type, either earthworms, musk shrews, or Norway rats. The prey type was determined by the maximum COPEC concentration among these prey types, thereby maximizing the estimated exposure in the monitor. As seen in Table 12, the estimated exposures in the mangrove monitor lizard are all less than those of the feral dog and Micronesian starling. In the latter case, they are typically one to two orders of magnitude less. These data indicate that unless reptiles are much more highly sensitive to the COPECs at IRP Site 39/Harmon Substation than are birds and mammals, risk to the monitor lizard is expected to be less than to the Micronesian starling and probably less than that to the dog.

AL/7-99/WP/Andersen:Eco-risk_AppM_AgencyDraft DOC 4-4 919689.21.00.60 30 7/28/99 5:02 PM Table 12 Comparison of Exposures in the Mangrove Monitor Lizard to Those in the Feral Dog and Micronesian Starling for Constituents of Potential Ecological Concern, IRP Site 39, Harmon Substation Andersen Air Force Base, Guam

Micronesian Starling Feral Dog Mangrove Monitor Lizard Exposure Exposure Exposure Constituent (mg/kg-d) (mg/kcj-d) (mg/kg-d)a Inorganic Lead 5.48E+0 4.01 E-1 5.30E-2 Volatile and Semivolatile Organics Acetone 9.32E-3 4.45E-3 9.81 E-5 Anthracene 1.23E-2 2.52E-4 1 .32E-4 Benzo(a)anthracene 2.31 E+0 1.88E-1 2.49E-2 Benzo(a)pyrene 4.38E-2 8.71 E-3 8.08E-4 Benzo(b)fluoranthene 6.64E-2 3.18E-2 3.05E-3 Benzo(k)fluoranthene 2.23E-2 1.82E-2 1.76E-3 Chrysene 2.01 E-2 2.77E-3 2.50E-4 Dibenzo(a,h,)anthracene 2.51 E-2 1.05E-2 1 .OOE-3 Fluoranthene 8.72E+0 2.61 E-1 9.37E-2 lndeno(1 ,2,3-cd)pyrene 1.09E-1 5.34 E-2 5.13E-3 Methylene chloride 3.63E-4 2.48E-5 3.85E-6 Phenanthrene 2.926+0 6.49E-2 3.13E-2 Pyrene 6.38E+0 3.29E-1 6.86E-2 Pesticides gamma-Chiordane 9.73E-4 2.88E-4 2.72E-5 4,4'-DDD 1.10E-2 4.87E-3 4.66E-4 4,4'-DDE 7.08E-1 3.14E-1 3. 01 E-2 4,4'-DDT 4.31 E-2 1.91 E-2 1.83E-3 Dieldrin 3.92E-3 2.18E-4 4.22E-5 Endrin aldehyde 2.23E-3 8.06E-5 2.40E-5 Heptachlor epoxide 2.19E-3 7.37E-5 2.36E-5 Polychiorinated Biphenyls Aroclor-1254 1.04E-1 1 .80 E-2 1.66E-3 Dioxins/Furans TCDD equivalent 1.30E-3 1 .03E-4 | 3.49E-5 aBased on 100 percent consumption of prey with maximum constituent concentration.

AL/7-99/WP/Andersen:Eco-risk_AppM_AgcncyDraft.DOC 4-5 919689.21.00.60.307/28/995:02 PM 4.3 Uncertainty Analysis A wide variety of factors contribute to the uncertainty associated with this ecological risk evaluation. Uncertainty is inherent in all aspects of the risk process, including the selection of indicator species, the estimation of exposure in these selected receptors, the characterization of potential ecological effects related to this exposure, and the final evaluation of risk to these receptors. For this assessment, conservatism was incorporated at many points in the process to provide assurance that these uncertainties do not lead to an underestimation of the actual risk to the ecological receptors at a site. Conservatisms, therefore, are more likely to lead to an overestimation of the actual risk posed by the COPECs at a site. This is especially true when multiple conservatisms are used, resulting in a multiplicative effect on the overestimation of risk. For this reason, the interpretation of the risk results of this evaluation must be made in light of the potential effects of the conservatisms used in obtaining the risk result. The purpose of this evaluation is to identify whether COPECs can be eliminated from further consideration based on a high probability that the HQs exceeding unity in Table 11 can be attributed to conservative assumptions used in the estimation of exposure and/or the determination of the toxicity benchmark rather than indicating actual risk to ecological receptors.

A general area of uncertainty for all HQs in this assessment is the bioavailability of the COPECs at the site. In general, toxicity tests are performed using chemical amendments to food or soil that are highly available to the test organism. It is conservatively assumed in this assessment that the COPECs in the soil at IRP Site 39/Harmon Substation are as available as those in the test organisms used to determine the toxicity benchmark. Under field conditions, however, depth, age, and soil characteristics will affect bioavailability, generally making the COPECs less available to receptors than in the laboratory conditions. The potential effects of other uncertainties on specific HQ results are further discussed below.

The 95-percent UCL of phenanthrene in the soil at IRP Site 39/Harmon Substation resulted in an HQ of 1.47 for the musk shrew. A principal source of uncertainty in this HQ is that phenanthrene-specific toxicity information could not be found; therefore, the toxicity benchmark is conservatively based on the NOAEL of benzo(a)pyrene, which is relatively highly toxic to wildlife. Other conservatisms incorporated in this HQ are the use 100 percent earthworm ingestion for the shrew, the use of the low-range total organic carbon content in the soil (which maximizes the soil-to-earthworm transfer factor), and the use of the 95-percent UCL of the soil concentrations as the exposure point concentration, which is approximately 1.8-times higher than the calculated mean soil concentration of phenanthrene. These factors, in combination, are

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft DOC 4.5 919689 21 00 60 30 7/28/99 5 02 PM sufficient to indicate that the probably of risk to the musk shrew and other insectivorous small mammals from exposure to phenanthrene at IRP Site 39/Harmon Substation is negligible.

The 95-percent UCL of lead in the soil at IRP Site 39/Harmon Substation resulted in an HQ of 4.42 for the Micronesian starling. A principal source of uncertainty in this HQ is the use of the most conservative NOAEL as the toxicity benchmark for this receptor. The NOAEL is based on a study that used Japanese quail (Coturnixjaponicd) which found the LOAEL to be 11.3 mg/kg- d) and the NOAEL (corresponding to the next lower dose tested, using increments of 1 Ox) to be 1.13 mg/kg-d (Sample et al., 1996). Another study, using American kestrels (Falco spar\>erius) found a NOAEL of 3.85 mg/kg-d (Sample et al., 1996), Neither of these test species is more closely related to the Micronesian starling than the other. Using the NOAEL from the American kestrel, the HQ for the starling would be 1.26. Another conservatism incorporated in this HQ is the use 100 percent earthworm ingestion for the starling (which does eat a variety of food types, including plant material). The estimated concentration of lead in earthworms (at the 95 percent UCL soil concentration) is about 4 times greater than that in plants, indicating that a more realistic dietary mix for this receptor will further reduce its estimated exposure. These factors are sufficient to indicate that the probably of risk to the Micronesian starling and other insectivorous birds from exposure to lead at IRP Site 39/Harmon substation is negligible.

The 95-percent UCLs for 4,4'-DDE and 4,4'-DDT in the soil at IRP Site 39/Harmon Substation also resulted in an HQ greater than unity for the Micronesian starling. The principal source of uncertainty in these HQs is the use of the most conservative NOAEL as the toxicity benchmark for this receptor. The NOAEL is based on a field study of brown pelican (Pelecanus occidentalis) reproduction success as related to DDT concentrations in fish. This study found a NOAEL of 0.0028 mg/kg-d (Sample et al., 1996); however, other potentially toxic constituents were also present in these fish. A controlled study using American kestrels found a LOAEL of 0.87 mg/kg-d (Peakall et al., 1973), from which a NOAEL of 0.087 mg/kg-d has been estimated (EPA, 1995). Neither of these test species is more closely related to the Micronesian starling than the other. The less conservative toxicity benchmark results in HQs for 4,4'-DDE and 4,4'- DDT of 0.321 and 0.0374, respectively. Therefore, actual risk to the Micronesian starling (and other insectivorous birds) from exposure to these two compounds is dubious. Furthermore, as with lead, the concentrations of 4,4'-DDE and 4,4'-DDT in earthworms are about 40-times greater than the concentrations in plants. Therefore, a more realistic dietary mix for this species will significantly reduce the predicted exposure.

A177-99AVP/Andersen:Eco-risk_AppM_AgencyDraft.DOC 4.7 919689.21.00.60,307/28/995:02 PM The 95-percent UCLs for the dioxins and furans (as TCDD equivalent) in the soil at IRP Site 39/Harmon Substation resulted in HQs greater than unity for all ecological receptors for which - toxicity information was available (excludes sword grass and the mangrove monitor lizard). The HQs ranged from 8.5 (for the feral dog) to 124 (for the musk shrew). One source of uncertainty for these HQs is the use of TEQs to evaluate all dioxins and furans on the basis of an estimated equivalence to TCDD. The TEFs upon which the TEQs are based are essentially "order-of- magnitude"-level approximations of relative toxicity and therefore may lead to significant overestimations or underestimations of risk. The use of TEQs to estimate risk for total dioxins and furans also assumes that the toxic effects are additive for the included compounds (Van den Berg et al., 1998).

Another source of uncertainty in these HQs is the derivation of the toxicity benchmark values for TCDD (upon which the final HQ is based). For this assessment, the toxicity benchmarks for TCDD in both mammals and birds are based upon studies which there was a 10-fold difference between the LOAEL concentration and the NOAEL concentration. Because the NOAEL-based HQs for the Micronesian starling and feral dog were less than 10, the HQs for the LOAEL would be less than unity for these receptors and related receptors.

Other sources of uncertainty in the TCDD HQs include receptor diets that emphasize animal prey over plants and the use of 95-percent UCLs to calculate the exposure point concentrations rather than the means. For TCDD, concentrations in earthworms are estimated to be 767-times those in plants. Therefore, the dietary mix can significantly affect the exposure estimation. If the calculated means of the samples are used to determine the exposure point concentration (as TCDD-equivalent), the HQs for the shrew, rat, starling, and dog are 45.9, 8.99, 3.75, and 3.31, respectively. One sample (HAS39S155), which was included in the database for this assessment, had questionably high concentrations for PCDDs and PCDFs. Resampling of this location did not confirm these high concentrations (OHM, February 11, 1999). Excluding this sample (but retaining the resample data) reduces the means for the PCDDs and PCDFs such that the HQs for the shrew, rat, starling, and dog are 15.6, 3.04,1.81, and 1.19, respectively. Although the combined effects of these factors make the possibility for the existence of actual risk to the Micronesian starling, the feral dog, and (probably) the Norway rat from exposure to dioxins and furans dubious, they may not be sufficient to eliminate the possible existence of risk to the musk shrew. This is also true for other species contained within the trophic levels that these animals represent.

AU7-99/WP/AndCTsen:Eco-nsk_AppM_AgencyDraft.DOC 4.5 919689.2100 60.30 7/28/99 5.02 PM 4.4 Ecological Significance This section involves the examination of the conservatism assumptions incorporated into the prediction of risk as they relate to the biological and ecological factors associated with the receptors within the context of the existing site conditions. Aspects that are addressed include the following:

• Foraging range/home range • Seasonal use patterns • Habitat quality • Population level impacts • Community level impacts

IRP Site 39/Harmon Substation is approximately 8 acres in area, and is highly disturbed due to past site use, remediation, and surrounding land use. The results of this risk assessment indicate that continued colonization of the site by plants will not be inhibited by residual chemicals in the soil. In fact, future succession of the plant community is largely dependent upon future use and/or disturbance of the site and surrounding areas. Based on current conditions, the site is not expected to revert to a native vegetation climax community. Exposures in all wildlife receptors were estimated based on the assumptions that the foraging range of the receptor equaled the size of the site (i.e., the home range factor equaled 1), that no differences in use exist between seasons (i.e., the seasonal use factor equals 1), and that the COPECs at this site are 100 percent bioavailable. The size and remoteness of Guam, and the generally nonseasonal character of its climate indicate that the assumption of nonseasonal use of the site by the wildlife receptors valid.

Also, as stated earlier, the assumption of a home range factor of 1 is probably valid for the musk shrew and Norway rat. Most birds of the size of the Micronesian starling have home ranges greater than 8 acres (Schoener, 1968), although such species as the American robin (Turdus migratorius) and western meadowlark (Sturnella neglecta), which are about the size of the Micronesian starling, can have territorial ranges less than 8 acres. Therefore, it is likely that the assumption of a home range factor of 1 for the starling results in an overestimation of the expected exposure to these or similarly sized birds, especially given the poor quality of the habitat at this site; however, this assumption cannot be ruled out as an extreme case. Similarly, the range of a large mangrove monitor lizard probably exceeds the size of the site. However, based on the relationship between body size and home range in lizards found by Turner et al. (1969), monitors of about 200 grams or less could have home ranges smaller than this site. Wild canids, such as coyotes (Canis latrans) (to use as a model for the feral dog) have home ranges of 6 square miles (approximately 4,000 acres) or more (Lindstedt et al., 1986). Therefore, the

AL/7-99/WP/Andersen.Eco-nsk_AppM_AgencyDran.DOC 4,9 919689.21.00.60.30 7/28/99 5:02 PM assumption of a home range use factor of 1 for this species and similar species will lead to large overestimations of exposure.

Whether the current habitat conditions allow for these wildlife receptors or similar species to be present on the site is not known. The site is of poor habitat quality and its use by wildlife will be inhibited by these conditions and by surrounding development and land use. The results of this assessment assume the site could support a sufficient food-base of earthworms to allow insectivorous mammals, birds, and reptiles to be completely supported by the habitat on the site. . Based on the current site conditions, this assumption is highly conservative. Furthermore, the toxicity benchmarks used in this assessment are based on effects to individuals. For both TCDD and 4,4'-DDT and its metabolites, the endpoints of these benchmarks are reduced reproduction. Because of the small size of the site and its location in disturbed habitat, it is unlikely that the few individuals that may be affected by exposures at this site will significantly affect local population size or the local biological community. Although the Micronesian starling is listed as endangered, and therefore, risks to individuals is of concern, it does not currently occur on the site. Under current conditions, therefore, risks to this species are considered negligible.

4.5 Scientific/Management Decision Point Once HQs are calculated and comparisons are made against screening criteria, the evaluation of ecological risk is examined to determine the reasonableness of the risk prediction. A risk management decision is made based on potential risk and the remedial options currently being considered. Possible risk management decisions, according to EPA (1997), are as follows:

• There is adequate information to conclude that the ecological risks are negligible and the ecological risk evaluation supports no further investigation or remediation

• There are sufficient lines of evidence to document potential or actual adverse ecological effects. Thus, additional data collection and a revision of the risk assessment or remediation may be warranted

• There is insufficient information to make an ecological screening decision, and site- specific data needs should be re-evaluated and additional data should be collected

Each of the listed decisions are evaluated and a recommendation made based exclusively on information obtained through the ecological risk assessment itself.

The results of this screening level assessment indicate no inorganics, volatile organic compounds, PAHs, or PCBs present significant risk to terrestrial receptors at this site. Potential

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC 4-10 919689.21.00.60.307/28/995:02 PM risks to insectivorous birds from exposures to 4,4'-DDT and 4,4'-DDE were initially identified under the most conservative modeling conditions; however, the evaluation of uncertainties associated with these predictions makes such predictions of risk dubious. The screening level assessment identified potential risk to all wildlife receptors from exposures to dioxins and furans. Factors associated with uncertainties and ecological significance support the conclusions that these risk predictions for the Micronesian starling and feral dog (and thereby indirectly predicted for the mangrove monitor lizard) are overestimations and that the actual risks are negligible. This may also be true for the Norway rat, but the musk shrew, if present on the site, may be adversely affected by dioxins and furans. Because the site is small and highly disturbed, and is not located in important natural habitat, and because neither the Norway rat nor the musk shrew represent ecologically significant receptor species or trophic levels (all other small mammals, except for a few species of bats, are considered pest-species on Guam), it is concluded that the overall ecological risks at this site are negligible and that there is adequate information to conclude that no further investigation or remediation are required.

AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDraft.DOC 4,j j 919689.2! 00 60 30 7/28/99 5.02 PM 5.0 Summary

This screening level ecological risk assessment was performed in accordance with federal and regional EPA guidance on ecological risk assessment (EPA, 1992; EPA, 1997; EPA, 1998a; Callahan, 1998). Both conservative and realistic assumptions were used in the evaluation of potential risk to biota that may use the site either at present or in the future. Ecological receptors selected to represent key trophic levels at the site were a generic plant, musk shrew, Norway rat, feral dog, Micronesian starling, and the mangrove monitor lizard. Emphasis in this assessment was on the protection of upper trophic levels species. The results of this screening level assessment indicate no inorganic analytes (limited to lead), volatile organic compounds, PAHs, or PCBs present significant risk to terrestrial receptors at this site.

Potential risks to insectivorous birds from exposures to 4,4'-DDE and 4,4'-DDT were initially identified under the most conservative modeling conditions; however, the evaluation of uncertainties associated with these predictions makes such predictions of risk dubious and the actual risk is probably negligible. The screening level assessment identified potential risk to all wildlife receptors from exposures to dioxins and furans. Factors associated with uncertainties and ecological significance support the conclusions that these risk predictions for the insectivorous bird and predatory mammal (and thereby indirectly predicted for the predatory reptile) are overestimations and that the actual risks to these receptors are negligible. This may also be true for the omnivorous small mammal, but the predicted risk to the insectivorous small mammal was relatively high, and if this species is present on the site, it may be adversely affected by exposure to dioxins and furans through a diet high in earthworms. However, because the site is small (approximately 8 acres), highly disturbed, and is not located in important natural habitat, and because the small mammals do not represent ecologically significant or protected species, it is concluded that the overall ecological risks at this site are negligible and that there is adequate information to conclude that no further investigation or remediation are required.

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Al77-99/WP/Andeisen:Eco-nsk_AppM^AgencyDraft.DOC £_2 919689.21.00 60.30 7/28/99 5:02 PM National Council on Radiation Protection and Measurements (NCRP), 1989, "Screening Techniques for Determining Compliance with Environmental Standards: Releases of Radionuclides to the Atmosphere," NCRP Commentary No. 3, Revision of January 1989, National Council on Radiation Protection and Measurements, Bethesda, Maryland. NCRP, see National Council on Radiation Protection and Measurements. OHM, see OHM Remediation Services Corp.

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AL/7-99/WP/Andersen:Eco-nsk_AppM_AgencyDran DOC . 919689.21.00 60 30 7/28/99 5 02 PM OHM Remediation Services Corp. (OHM), January 16,1999, Memo from D. F. DeSario (OHM Project TM) to J. Poland (Andersen AFB Remedial PM) and J. Hill (AFCEE) titled, "IRP Site 39/Harmon'Substation, Buried Drum Area Remediation."

OHM Remediation Services Corp. (OHM), January 22,1999, Memo from D. F. DeSario (OHM Project TM) to J. Poland (Andersen AFB Remedial PM) and J. Hill (AFCEE) titled, "IRP Site 39/Harmon Substation, Miscellaneous Container Area Remediation - Segments 3 &4."

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OHM Remediation Services Corp. (OHM), February 24,1999, Memo from D. F. DeSario (OHM Project TM) to J. Poland (Andersen AFB Remedial PM) and J. Hill (AFCEE) titled, "IRP Site 39/Harmon Substation, Buried Drum Area Test Pit Investigation."

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